Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 11

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          other means, such as by showing Weimerskirch's net worth, bank              
          deposits, cash expenditures, or source and application of funds.”           
          Id.  Additionally, in Weimerskirch, the taxpayer was not shown by           
          admissible evidence to have actually possessed any of the funds             
          that the Commissioner determined to be taxable income.  In the              
          instant case, the various petitioners were connected to the funds           
          forming the basis of the deficiency by respondent's analysis of             
          bank deposits and expenditures.  “[C]onnecting * * * [the                   
          taxpayer] to the funds that form the basis of the deficiency is             
          sufficient to give him the burden of proving the deficiency                 
          determination erroneous.”  Schad v. Commissioner, 87 T.C. at 620.           
               Respondent has substantiated her determination with                    
          predicate evidence; she used the bank deposits and cash                     
          expenditures method of income reconstruction.  See Blohm v.                 
          Commissioner, 994 F.2d 1542, 1549 (11th Cir. 1993), affg. T.C.              
          Memo. 1991-636 (once the Tax Court has found the Commissioner has           
          made a minimal evidentiary showing, the deficiency determination            
          is presumed correct); Erickson v. Commissioner, 937 F.2d 1548,              
          1551 (10th Cir. 1991), affg. T.C. Memo. 1989-552 (the key is                
          connecting taxpayers to assets, not to a business).  The burden             
          of proof therefore lies with petitioners to show error in                   
          respondent's determinations.                                                
          Unreported Income--the Dickersons                                           
               Revenue Agent Anita Russell, using a bank deposits analysis,           
          determined that the Dickersons had unreported income in the                 

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