Salaheddin Ahmad Ahmad - Page 15

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          T.C. 858, 867 (1991), affd. 959 F.2d 16 (2d Cir. 1992).  Though             
          not conclusive, bank deposits are prima facie evidence of income.           
          Price v. United States, 335 F.2d 671, 677 (5th Cir. 1964) (the              
          bank deposits method assumes that all money deposited in a                  
          taxpayer's bank account during a given period constitutes taxable           
          income);15 Tokarski v. Commissioner, 87 T.C. 74, 77 (1986);                 
          Estate of Mason v. Commissioner, 64 T.C. 651, 656-657 (1975),               
          affd. 566 F.2d 2 (6th Cir. 1977); Jones v. Commissioner, 29 T.C.            
          601 (1957).  Where the taxpayer has failed to maintain adequate             
          records as to the amount and source of his income, and the                  
          Commissioner has determined that the deposits are income, the               
          taxpayer has the burden of showing that the determination is                
          incorrect.  Rule 142(a); Clayton v. Commissioner, 102 T.C. 632,             
          645 (1994); Parks v. Commissioner, supra; Estate of Mason v.                
          Commissioner, supra.  Furthermore, in such cases the Commissioner           
          is not required to show a likely source of income.  Clayton v.              
          Commissioner, supra; Parks v. Commissioner, supra; Estate of                
          Mason v. Commissioner, supra.                                               
               In challenging respondent's income reconstruction,                     
          petitioner introduced evidence that was intended to corroborate             
          his claim that the deposits were due to nontaxable sources.  This           


          15     In Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th             
          Cir. 1981) (en banc), the Court of Appeals for the Eleventh                 
          Circuit adopted as binding precedent all of the decisions of the            
          former Court of Appeals for the Fifth Circuit handed down prior             
          to the close of business on Sept. 30, 1981.                                 




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