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(1991), affd. 959 F.2d 16 (2d Cir. 1992). Because petitioner
failed to produce books and records, respondent reconstructed his
income from bank deposits. Respondent's reconstruction consisted
of adding petitioner's deposits, identifying any deposits which
represented interaccount transfers, and identifying duplications
with the IRP information. At trial, respondent further made
reductions in the bank deposits calculation. Petitioner has
failed to show that respondent improperly reconstructed his gross
income. Indeed, respondent has provided sufficient evidence to
convince this Court that the notice of deficiency was neither
arbitrary nor unreasonable. Therefore, the burden rests with
petitioner to demonstrate that respondent's determinations are
erroneous. Rule 142(a).
Petitioner has introduced no credible evidence that
disproves any element of respondent's deficiency determination.
Petitioner failed to produce books or records. However, we shall
address several issues petitioner raised at trial regarding the
accuracy of respondent's determinations. First, petitioner
testified that while he was employed as a public insurance
adjuster, he deposited funds into his account and later
transferred a portion of the same funds to his clients. However,
petitioner failed to offer any evidence regarding the specifics
of these alleged transfers to alleged clients. He produced no
canceled checks, witnesses, or other records. We find that
petitioner's vague and self-serving testimony does not substitute
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