David D. Parrish - Page 6

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               Based on the results of Agent Stacks' audit, respondent on             
          July 20, 1995, issued a notice of deficiency to petitioner.                 
          Respondent subsequently conceded that Agent Stacks made an error            
          in the analysis relating to petitioner's 1989 tax year and now              
          contends that the correct amount of unreported income for 1989 is           
          $238,834.27 rather than the $386,663 earlier determined.                    
                                       OPINION                                        
               Respondent's determinations are presumed to be correct, and            
          petitioner bears the burden of proving them erroneous.  Rule                
          142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933); Mattingly             
          v. United States, 924 F.2d 785, 787 (8th Cir. 1991).                        
          I.  Unreported Income                                                       
               Gross income includes all income from whatever source                  
          derived.  Sec. 61(a).  If a taxpayer fails to maintain adequate             
          records of taxable income, the Commissioner may reconstruct                 
          income in accordance with a method that clearly reflects the full           
          amount of income received.  Sec. 446(b); Rowell v. Commissioner,            
          884 F.2d 1085, 1087 (8th Cir. 1989), affg. T.C. Memo. 1988-410;             
          Meneguzzo v. Commissioner, 43 T.C. 824, 831 (1965).                         
               Respondent used the bank deposits method to reconstruct                
          petitioner's income for 1988 and 1989.  Bank deposits are prima             
          facie evidence of income, Tokarski v. Commissioner, 87 T.C. 74,             
          77 (1986), and under the bank deposits method, all money                    
          deposited into a taxpayer's bank account during a given period is           





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