John R. Boone, Jr. - Page 19

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          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 is              






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