- 27 - Commissioner, supra at 873-874, the record shows that respondent investigated petitioner’s claims of nontaxable sources and showed them to be implausible and/or not supported by objective evidence in the record, United States v. Conaway, supra at 44; Parks v. Commissioner, supra at 661. Respondent has thus established an underpayment for 1987. 1988 and 1989 In contrast to the approach used for 1987, respondent determined that petitioner underpaid his 1988 and 1989 taxes, not on the basis of deposits into Pieces of Eight’s bank account, but on the basis of expenditures from the account. Respondent does not argue on brief that the method used to determine the underpayments of tax for 1988 and 1989 was the bank deposit method or any variation thereof. Respondent’s agent examined the checks drawn on the account of Pieces of Eight and treated as personal or nondeductible the expenditures that could not be associated with that business. Respondent did not place in evidence any analysis of bank deposits for Pieces of Eight during those years, although respondent’s agent claimed to have gone through its bank deposits. Respondent has offered no explanation why the determination of the underpayment of tax apparently was based on only an analysis of expenditures from Pieces of Eight’s bank account, and not on deposits into the account.9 9 For instance, respondent does not claim that records of (continued...)Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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