- 7 - is not required to trace deposits to their source. Petzoldt v. Commissioner, supra at 695-696; Estate of Mason v. Commissioner, supra at 657. Respondent's revenue agent analyzed petitioners' bank accounts. She took the net deposits shown on the bank statements, added back any cash withheld, and subtracted out any deposits that were identifiable as nontaxable. Petitioners argued at trial5 that their check registers show their gross income. We find the check registers to be unreliable as they do not tie in with petitioners' bank statements. Petitioners conceded at trial that they did not report any income from magic shows or band activities. Petitioners further argue that the cash deposits into their bank accounts are not income because the cash came from other bank accounts. Petitioners, however, have offered no proof to support their claim other than vague, uncorroborated testimony. Petitioners failed to prove that respondent's reconstruction of income is incorrect. Rule 142(a). Therefore, we sustain respondent's determination on this issue. B. Deduction for Mileage Petitioners admitted that their auto logs were estimates and not contemporaneously made, as required by section 1.274- 5(c)(2)(ii)(a), Income Tax Regs. Respondent allowed petitioners' 5 Petitioners' brief consists of a two-page letter in which they assert that no additional tax is owed. The mileage and negligence issues are not addressed.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011