- 20 - Petitioner claims that he did not file income tax returns for the years in issue because he received no salary or wages and because he earned no income. In our consideration of the fraud addition to tax, we must consider petitioner’s taxability on the specific items of income and on the deposits into his bank accounts and petitioner’s claimed losses and expenses in light of the placement of the burden of proof on respondent by clear and convincing evidence. For 1984, 1985, 1987, 1988, and 1989, the specific items that we have charged to petitioner as income are established by clear and convincing evidence, and the large expenses and losses that petitioner claims are not supported by any credible evidence. With regard to the income charged to petitioner under the bank deposits method of proof, respondent has established likely taxable sources of the bank deposits, and petitioner makes no credible argument as to nontaxable sources of those deposits. Accordingly, for fraud purposes, we treat all of the unexplained bank deposits as additional income to petitioner. In the schedule below and for purposes of analyzing the imposition of the fraud addition to tax, we set forth our calculations of petitioner’s net income for each year in issue, reflecting all expenses and losses that are allowed by respondent and that are allowed herein:Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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