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assert that it would have been impossible for those restaurants
to generate the sales necessary to produce the amount of
unreported income determined by respondent. Petitioners maintain
that the restaurants' method of accounting for cash assured that
all cash was accounted for and that there was no skimming of cash
during the years in issue.
Bank deposits are prima facie evidence of income. Tokarski
v. Commissioner, 87 T.C. at 77; see also United States v.
Conaway, 11 F.3d 40, 43 (5th Cir. 1993) ("the evidence of bank
deposits suffices to raise the inference that the taxpayer's
income came from a taxable source"). We have decided above that
the Takaos had unreported income as evidenced by unexplained bank
deposits and cash purchases. Respondent need not prove a likely
source of that unreported income. Petzoldt v. Commissioner, 92
T.C. at 695-696; Tokarski v. Commissioner, supra at 77. Here,
however, a likely source exists in sales receipts of the
restaurant owned by them and the restaurants owned by Toraya, of
which the Takaos were the sole shareholders. Petitioners bear
the burden of proving that Toraya did not underreport its income.
Rule 142(a); Calhoun v. United States, 591 F.2d at 1245;
Truesdell v. Commissioner, 89 T.C. 1280 (1987).
Petitioners presented expert testimony by John Shimmon
(Shimmon) in support of their contention that the restaurants
could not have unreported sales receipts. Shimmon stated that in
the restaurant business the difference between cost of sales and
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