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income by any method that clearly reflects income. Sec. 446(b);
Holland v. United States, 348 U.S. 121 (1954); Webb v.
Commissioner, 394 F.2d 366, 371-372 (5th Cir. 1968), affg. T.C.
Memo. 1966-81. The reconstruction of income need only be
reasonable in light of all surrounding facts and circumstances.
Giddio v. Commissioner, 54 T.C. 1530, 1533 (1970). The
Commissioner is given latitude in determining which method of
reconstruction to apply when a taxpayer fails to maintain
records. Petzoldt v. Commissioner, 92 T.C. 661, 693 (1989).
For the years in question, we find that petitioner
maintained inadequate books and records.5 Respondent employed
the bank deposits method of proof to reconstruct petitioner's
gross receipts from his medical practice. This method of proof
is well established. DiLeo v. Commissioner, supra at 867; Estate
of Mason v. Commissioner, 64 T.C. 651, 656 (1975), affd. 566 F.2d
2 (6th Cir. 1977). Bank deposits are prima facie evidence of
income. Tokarski v. Commissioner, 87 T.C. 74, 77 (1986); Estate
of Mason v. Commissioner, supra at 656-657. When using the bank
deposits method, the Commissioner is not required to show that
each deposit or part thereof constitutes income, Gemma v.
Commissioner, 46 T.C. 821, 833 (1966), or prove a likely source,
Clayton v. Commissioner, 102 T.C. 632, 645 (1994); Estate of
Mason v. Commissioner, supra at 657. Respondent's determination
5 The scanty evidence petitioner submitted as records
lacked indicia of reliability. See infra.
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