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funds deposited into his money market account at Merrill Lynch
and from his bank account at Guardian State Bank. Petitioner is
to be allowed these expenses as deductible business expenses.
Petitioner's claim to additional losses and expenses beyond those
allowed herein is not supported by the evidence and is denied.
We reject petitioner's general claim that over the years in
issue he never realized any bottom line net income and that he
realized over the years in issue total losses in excess of $20
million. No credible evidence supports the nature and amount of
petitioner's claim to total net losses in any of the years before
us.
Petitioner points to his bankruptcy filing and to the loss
of his residence, and petitioner argues that respondent should
have performed a net worth analysis of petitioner's income for
the years in issue. Petitioner alleges that such a net worth
analysis would have corroborated losses he claims to have
realized over the years. Respondent, in this case, is under no
obligation to make such a net worth computation. As indicated,
respondent is entitled to reconstruct petitioner's income by any
reasonable method. Erickson v. Commissioner, 937 F.2d at 1553;
United Dressed Beef Co. v. Commissioner, 23 T.C. at 885.
With the exceptions noted, we sustain respondent's
determination of petitioner's taxable income for each of the
years in issue under the specific item and the bank deposits
methods of proof.
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