Sarkis N. and Baka S. Balabanian - Page 8

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          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 analyze                    




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