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Helvering, 290 U.S. 111, 115 (1933); see also Sproul v.
Commissioner, T.C. Memo. 1995-207. Testimony of a taxpayer which
is unsupported by documentary evidence may be insufficient to
satisfy his or her burden. See Alvarez v. Commissioner, T.C.
Memo. 1995-414; Price v. Commissioner, supra.
In this case, respondent used the bank deposits method to
reconstruct petitioner's income. Petitioner argues that several
items which were deposited into petitioner's ACB account should
not constitute income. We will discuss each item in turn.
First, petitioner contends that $2,812 from the sale of
Jerrico, Inc. stock in 1984 and $9,507 from the sale of
Securities Settlement Corp. stock in 1985 should not be taxed as
unreported income. Respondent conceded in her brief that these
amounts are not taxable.
Second, petitioner contends that he borrowed $50,000 from
Ray Kaiser to open his insurance agency. Petitioner testified
that Mr. Kaiser first contacted him because Mr. Kaiser would be
receiving a $50,000 disability settlement and wanted to invest
the proceeds in an annuity from which he would receive an
adequate return. Petitioner testified that he suggested a
Prudential annuity, but Mr. Kaiser rejected it. Petitioner
testified that he deposited the funds into various savings and
loans but then withdrew the funds and kept them in a "secret
hiding spot" in his house because he was dissatisfied with the
return on investment he was receiving from the banks. Petitioner
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