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petitioner put into a safe deposit box in 1988. Furthermore,
petitioner filed a claim for the money seized from the boxes at
the California banks and for the Cadillac from which the $27,620
was seized. Finally, petitioner admits that he rented the boxes,
and that he put the money into the boxes.
Respondent has connected petitioner to the funds that form
the basis of the deficiency; the notice of deficiency was not
arbitrary. Delaney v. Commissioner, supra; Schad v.
Commissioner, supra; Tokarski v. Commissioner, supra.
Since respondent's deficiency notice was not arbitrary,
petitioner has the burden of going forward with the evidence as
well as the ultimate burden of persuasion. Dellacroce v.
Commissioner, supra at 280.
Every taxpayer is required to maintain adequate records of
taxable income. Sec. 6001. Petitioner did not file a Federal
income tax return or make any estimated Federal income tax
payments for any of the years at issue. Nor did he maintain
adequate records from which the amount of his income or Federal
income tax liability for any of the years at issue could be
computed. In the absence of such records, respondent may
reconstruct the taxpayer's income by any reasonable method that
clearly reflects income. Sec. 446(b); Holland v. United States,
348 U.S. 121, 130-132 (1954); Parks v. Commissioner, 94 T.C. 654,
658 (1990). Respondent used the specific items method of proof
to determine petitioner's income for the taxable years at issue.
This method requires proof of specific items of income that were
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