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alleges a nontaxable source, negate each nontaxable source
alleged by the taxpayer. United States v. Massei, 355 U.S. 595
(1958); Holland v. United States, 348 U.S. 121, 137-138 (1954);
Armes v. Commissioner, supra; Parks v. Commissioner, supra at
661. If the Commissioner connects the bank deposits to a likely
source of income, the finder of fact may properly conclude that
such deposits are income. Holland v. United States, supra; Armes
v. Commissioner, supra.
Respondent has the burden of proof in the instant case
because the issue before us pertains to an increased deficiency.
Rule 142(a). Moreover, because petitioner does not contend that
the deposits at issue stem from a nontaxable source, respondent
must connect the deposits to a likely source of income in order
to satisfy the burden of proof.
Respondent maintains that a preponderance of the evidence
indicates that the deposits at issue stem from a taxable source
of income. Specifically, it is respondent's contention that
petitioner conducted a bookkeeping business during 1991, and that
the deposits were made with checks that petitioner received in
exchange for services that she performed in connection with that
business. As support for this argument, respondent explains that
the checks at issue were deposited into petitioner's "business"
bank account. Respondent also explains that a majority of the
checks at issue were made payable to petitioner's business and
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