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of $4,999 and $1,148, respectively. After concessions, the sole
issue for decision is whether respondent has connected certain
bank deposits that petitioner made in 1991 to a likely source of
income.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
herein. Petitioner resided in St. Petersburg, Florida, at the
time she filed the petition in this case.
Petitioner failed to file a Federal income tax return for
taxable year 1991. As a result, respondent prepared a substitute
return for petitioner and subsequently issued a corresponding
notice of deficiency on August 9, 1994. Only one issue remains
unresolved, and it involves bank deposits that respondent
identified during an analysis of petitioner's bank accounts.
Respondent raised this issue by asserting an increased deficiency
based on unexplained bank deposits as discussed below.
While conducting the above-mentioned bank deposits analysis,
respondent identified unexplained deposits totaling $30,212.
Respondent subsequently concluded that most of these deposits
were explained and reduced this amount to $2,808.35. The
deposits remaining at issue consist exclusively of checks and
were made to an account entitled "Madigan and Company". The
1(...continued)
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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