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Appeals for the Fourth Circuit, the court to which any appeal of
this case is likely to go, is not clear with respect to income
from legal sources. See Williams v. Commissioner, supra at 763.
Whatever the position of the Court of Appeals for the Fourth
Circuit, however, the record in this case contains ample evidence
that petitioner received substantial amounts of unreported income
from various, legal sources during the years in issue. We have
found that petitioner made substantial deposits in bank accounts
during 1983, and during 1986 through 1992. “A bank deposit is
prima facie evidence of income and respondent need not prove a
likely source of that income.” Tokarski v. Commissioner, 87 T.C.
74, 77 (1986). For 1983, 1987, 1988, 1989, and 1990, such
deposits equal or exceed all of the cash items of income (self-
employment and rental income) charged to petitioner by
respondent. For 1984, 1985, 1986, and 1992, we have found that
petitioner either received items of gross income (e.g., rental
income) or reported on financial statements items of gross income
equal to what respondent charged her. For 1991, petitioner had
bank deposits and worked as a real estate and money broker
beginning in October; by indirect methods of proof, respondent
has provided evidence of substantial personal expenditures,
sufficient to explain the self-employment income charged to
petitioner for 1991. For 1993, petitioner admitted in her
bankruptcy proceeding monthly expenditures of $1,698.84, which
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