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Weimerskirch v. Commissioner, 596 F.2d 358, 360 (9th Cir. 1979),
revg. 67 T.C. 672 (1977).
In the notice of deficiency, respondent determined that
petitioner earned unreported self-employment income of $17,857
and $30,764 in 1992 and 1993, respectively. During audit,
respondent's agent was of the opinion that petitioner had a
wallpapering business from which she earned self-employment
income. Respondent used the bank deposit reconstruction method
to determine that petitioner earned unreported self-employment
income in 1992 of $17,857 in addition to the $14,715 income from
the Form W-2 Wage and Tax Statement issued by the bank where
petitioner worked. From documents filed with this Court, it
appears that respondent used the consumer price index (CPI)
rollover method to determine petitioner's 1993 unreported income
and used petitioner's 1992 income, as determined by respondent,
as the base year.4 Respondent determined that petitioner had
unreported income in 1993 of $33,894 and attributed $30,764 to
self-employment income. Respondent concedes that petitioner was
not engaged in a wallpapering business in either 1992 or 1993.
Respondent also expressly concedes that petitioner did not earn
unreported self-employment income in 1992 and that petitioner
4 The explanation of adjustments in the notice of deficiency
has not been filed with the Court.
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