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Source Amount
Cash deposits to accounts in United States $11,400
Deposits to accounts in Japan 81,933
Check from USA Publishing 2,000
Check from Toraya Apartments 2,000
Check from Alameda County 1,688
Deposits from unknown sources 10,081
Total 109,102
Less deposits to accounts in Japan
conceded 171,825
Unexplained deposits in issue 37,277
1 The Takaos agree that $10,108 of the $81,933 deposited to
accounts in Japan is taxable income from rents that was not
reported on their 1991 tax return.
As we stated supra, bank deposits are prima facie evidence
of income, and respondent need not prove its likely source.
Clayton v. Commissioner, 102 T.C. at 645; Petzoldt v.
Commissioner, 92 T.C. 661, 695-696 (1989); Tokarski v.
Commissioner, 87 T.C. at 77. Petitioners have the burden of
proving that the unexplained bank deposits came from a nontaxable
source. Calhoun v. United States, 591 F.2d at 1245; Ruark v.
Commissioner, 449 F.2d at 312.
Petitioners contend that a nontaxable source of the
unexplained bank deposits consists of cash sent to the Takaos
from Akiko's mother in Japan. Petitioners assert further that
another nontaxable source consists of a cash hoard that Akiko had
accumulated before January 1, 1988, from cash the Takaos received
between 1982 through 1987 from Akiko's parents, from interest
income ($389,621) paid to the Takaos between 1982 and 1987, and
from payments they received from the sales of the Silver Lake and
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