- 8 - Commissioner, 64 T.C. 651, 656-657 (1975), affd. 566 F.2d 2 (6th Cir. 1977). The parties stipulated that Agent Careswell's bank deposits analysis is correctly computed. Normally, when the Commissioner's agents have performed such an analysis, taxpayers attempt to show that the bank deposits analysis is faulty by identifying nontaxable deposits. By stipulating to the mathematical correctness of respondent's bank deposits analysis, petitioners are left with the option of either showing a method that more correctly reflects income or explaining why particular deposits are nontaxable. Petitioners argue that a check exchange analysis rather than a bank deposits analysis should be used to determine petitioners' taxable income. Petitioners, however, do not precisely explain how the bank deposits analysis should be adjusted to account for their theory. In particular, they do not account for the possibility that other likely and demonstrated sources of unreported income may be more accurately reflected by the bank deposits analysis. It is petitioners' obligation to show that particular deposits or amounts should be subtracted from the deposits computed by respondent. Parks v. Commissioner, 94 T.C. 654, 658 (1990). This petitioners have not done. Petitioners contend that we should rely on a modified version of the bank deposits analysis that was performed by Agent Careswell. Careswell prepared a check spread to analyzePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011