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computerized deposit analysis listing all of the third-party
payors who paid petitioner for medical services, the amounts
paid, and the bank account the payment was deposited into. Mr.
Dever subtracted out of his deposit analysis amounts that were
not for medical services. Mr. Dever determined that the amount
of petitioner's medical practice income deposited into the
various bank accounts was greater than the amount reported on
petitioner's 1985, 1986, 1987, and 1988 individual and Superior's
1988 corporate tax returns.
Petitioner's Criminal Tax Convictions
In United States v. Tandon, 111 F.3d 482 (6th Cir. 1997),
the U.S. Court of Appeals for the Sixth Circuit affirmed
petitioner's conviction for wilfully filing false individual
income tax returns for 1986, 1987, and 1988 in violation of
section 7206(1) and for wilfully assisting in the preparation and
presentation of a false corporate income tax return for Superior
for 1988 in violation of section 7206(2).
OPINION
Unreported Income
Every individual liable for tax is required to maintain
books and records sufficient to establish the amount of his or
her gross income. Sec. 6001; DiLeo v. Commissioner, 96 T.C. 858,
867 (1991), affd. 959 F.2d 16 (2d Cir. 1992). Where a taxpayer
fails to maintain or produce adequate books and records, the
Commissioner is authorized to compute the taxpayer's taxable
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