Pramod and Raj Tandon - Page 16

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          taxpayer's self-serving testimony that deposits to the taxpayer's           
          account were nontaxable loan deposits).                                     
               Respondent was also substantially justified in rejecting               
          petitioners' position regarding the corporate source of deposits            
          to petitioner's personal accounts.  Section 6001 imposes on                 
          petitioners an affirmative duty to maintain books and records               
          sufficient to support items reported on their returns.  With this           
          well-established law in mind, we think that it was reasonable for           
          respondent to make the adjustments pursuant to the bank deposits            
          analysis and to refuse to concede any of these adjustments until            
          he received and verified petitioners' substantiation for these              
          amounts.  See Harrison v. Commissioner, 854 F.2d 263, 265 (7th              
          Cir. 1988), affg. T.C. Memo. 1987-52; Sokol v. Commissioner,                
          supra at 765.  Respondent was not required to accept                        
          unconditionally petitioners' uncorroborated summary bank account            
          statements prepared by their accountant or petitioners' otherwise           
          unsubstantiated statements regarding nontaxable income flowing              
          from a corporate source.                                                    
               We also observe that petitioners ultimately conceded that              
          they failed to report 50 percent of the unreported income                   
          determined in the notice of deficiency.                                     
               Petitioners rely heavily on the fact that respondent's                 
          counsel agreed to settle this case for 50 percent of the                    
          unreported income determined in the notice of deficiency even               
          though he was given no more information than Revenue Agent Bacino           




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