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liability for 1987 without regard to items attributable to
Mrs. Zuckerman and using rates applicable to married persons
filing separately. The deficiency and additions to tax
recomputed in this manner are higher than those set forth in the
notice of deficiency:
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661
1987 $31,702 $7,950 $1,590 1
$7,926
1Fifty percent of the interest due on $31,702.
The increase in the deficiency results in large part from
respondent's assumption that the $18,423 of reported wage and
gambling income attributable to Mrs. Zuckerman was not the source
of any of the total $84,653 of deposits to petitioner's bank
accounts during the year, from which respondent concluded that
petitioner had $18,423 more unreported income than she had
originally determined. In her amended answer, respondent did not
recompute the deficiency and additions to tax for the 1986
taxable year.
OPINION
Respondent's determinations in the notice of deficiency are
presumed to be correct, and petitioner has the burden of proving
otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115
(1933). However, respondent has the burden of proving the
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