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determination in the notice of deficiency that petitioner had
$66,230 of unreported income for 1987 is accordingly sustained.
In the amended answer respondent asserted that the amount of
petitioner's unreported income for 1987 should be increased to
$84,653. The asserted increase of $18,423 is equal to income
reported as Mrs. Zuckerman's. Respondent, in her amended answer,
allowed no credit to petitioner for the amount of this reported
income because respondent assumed that the bank accounts analyzed
by the revenue agent were used solely for the deposit of
petitioner's own funds. Respondent did not attempt to confirm
the accuracy of this assumption, and there is reason for
skepticism. Two of the six accounts included in the analysis
were titled as joint accounts of both spouses, to which Mrs.
Zuckerman would naturally have had access. Because respondent's
assertion of an increased amount of unreported income results in
an increase in the deficiency, respondent bears the burden of
proof on this point. Rule 142(a). Respondent has failed to
carry that burden. We therefore reject the deficiency asserted
in respondent's amended answer insofar as it includes in
petitioner's gross income amounts equal to Mrs. Zuckerman's wages
and gambling winnings.
Other Issues Bearing on Tax Liabilities
Pursuant to section 6001 petitioner was obligated to
maintain records to substantiate his income and deductions. He
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