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determination. Respondent bears the burden of proof as to any
new matter. Rule 142(a).
Respondent did not question the revenue agent regarding this
alleged error in the notice of deficiency. Respondent presented
us with proof of bank deposits, constituting gross receipts, into
account number 62-00931 that she alleges were not included in the
notice of deficiency. Petitioners agree that respondent has
produced sufficient proof of this account balance, but they argue
that this proof is not sufficient proof that this amount was
omitted from respondent's determination in the notice of
deficiency. Respondent has attempted to bolster her position by
introducing a supporting schedule, a bank deposits account
summary, and a bank deposit detail prepared by the revenue agent
during the examination of petitioners' returns to show that this
account balance was omitted from the determination in the notice
of deficiency.
We have looked to these workpapers not for the truth of the
facts and figures contained therein but for the presence or
absence of deposits into account No. 62-00931. Upon examination
of the revenue agent's schedules, we can see that no deposits
were included for account No. 62-00931 for 1991 in calculations
on certain schedules. However, many of the schedules have
handwritten notations and various corrections that we cannot
reconcile with respondent's argument. Because of these apparent
revisions, we cannot be certain that these schedules reflect the
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