Eva J. Madigan - Page 5

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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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