- 19 - tools to determine unreported income by indirect methods of proof. Id.; United States v. Hiett, 581 F.2d 1199, 1200 (5th Cir. 1978). Petitioner asserts that, where the taxpayer's records are adequate, respondent cannot rely on indirect methods to reconstruct income. Leaving aside the question of whether petitioner's records were in fact adequate in the instant case, it is well settled that respondent's use of an indirect method of determining income is not confined to situations where the taxpayer has no books and records or where his books are inadequate. See, e.g., Holland v. United States, 348 U.S. 121, 133 (1954); Davis v. Commissioner, 239 F.2d 187 (7th Cir. 1956), affg. T.C. Memo. 1955-87; Goichman v. Commissioner, T.C. Memo. 1987-489; Estate of Hanna v. Commissioner, T.C. Memo. 1976-32. In the instant case, respondent relies upon the bank deposits and cash expenditures method to show an improper omission of income. The propriety of the bank deposits and cash expenditures method of income reconstruction is well established. See, e.g., Caulfield v. Commissioner, 33 F.3d 991, 992 (8th Cir. 1994), affg. T.C. Memo. 1993-423; United States v. Abodeely, supra at 1023; Parks v. Commissioner, 94 T.C. 654, 658 (1990). The bank deposits and cash expenditures method is an offshoot of the bank deposits method. The bank deposits and cash expenditures method is used by respondent to prove the existence of omitted or unreported income in circumstances where cash isPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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