Maurzal Frias and Teresa Frias - Page 7

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          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.                                        



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