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supra at 1549; Erickson v. Commissioner, 937 F.2d 1548, 1551
(10th Cir. 1991). Once this minimal evidentiary showing has been
made, the deficiency determination is presumed correct, and it
becomes the taxpayer's burden to prove it erroneous. Blohm v.
Commissioner, supra at 1549. Testimony of a taxpayer which is
unsupported by documentary evidence may be insufficient to
satisfy the taxpayer's burden. See Ghadiri v. Commissioner, T.C.
Memo. 1996-528; Alvarez v. Commissioner, T.C. Memo. 1995-414.
In Fitzpatrick v. Commissioner, T.C. Memo. 1995-548, the
Court held that petitioner was collaterally estopped from denying
his participation in the bribery scheme. Remaining in issue is
the amount of unreported income he received in 1981 and 1982. We
find that petitioner has not met his burden of proving that the
amounts he directed Landing to deposit in the R&S and Pares Y
Nones, S.A. accounts are not includable in his gross income.
Further, petitioner has not proven that the repairs to his home
which Landing paid for did not constitute income to him.
Respondent argues that petitioner should include in income
the deposits into the R&S and Pares Y Nones, S.A. accounts and
that he exercised dominion and control over those accounts. We
agree with respondent. All of the deposits to the R&S account
came from the Bank's construction loan clients to whom petitioner
rendered services, and all of the disbursements from the account
were made by checks drawn on the account that were signed either
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