- 11 - 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 thePage: 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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