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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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