-9- of Mason v. Commissioner, 64 T.C. 651, 656 (1975), affd. 566 F.2d 2 (6th Cir. 1977). Bank deposits are prima facie evidence of income. Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). In a cash expenditures analysis, the amount by which a taxpayer's cash expenditures exceeds his known sources of income is assumed to be taxable income, unless the taxpayer can show the expenditures were made from a nontaxable source. DeVenney v. Commissioner, 85 T.C. 927, 930 (1985). In analyzing the bank deposits, the revenue agent separated cash, checks, cashier's checks, and wire transfers. She examined the source of each deposit. She separated those items subject to self-employment tax, such as presumed receipts from the restaurants, from those items not subject to self-employment tax, such as rental income. These appeared as separate adjustments in the notice of deficiency with respect to Ms. Ng. To the extent possible the revenue agent eliminated those items that had been reported or came from nontaxable sources, such as transfers and refinancing proceeds. The revenue agent also subtracted from unidentified cash deposits the maximum amount of reported rents that could have been paid in cash or by check; moreover, she subtracted substantiated partnership draws paid directly to Ms. Ng by Golden Dragon Restaurant. We are satisfied that the revenue agent gave Ms. Ng credit for every nontaxable source of income that could be identified. Moreover, before the trial, respondent conceded certain nontaxable items that becamePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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