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for computing income. Estate of Mason v. Commissioner, 64 T.C.
651, 656-657 (1975), affd. 566 F.2d 2 (6th Cir. 1977).
Petitioner bears the burden of proving that respondent's
determinations, including unreported income, are incorrect. Rule
142(a); Nicholas v. Commissioner, 70 T.C. 1057, 1064 (1978).
In the notice of deficiency, respondent determined that
petitioner failed to report $344,225 of gross receipts from his
business practice in 1990, $666,563 in 1991, and $231,212 in
1992. For the 1990 and 1991 taxable years, petitioner has not
contested that the deposits into the accounts were income from
his medical practice. Therefore, we find that petitioner failed
to report $344,225 of gross receipts from his business for 1990
and $666,563 for 1991.
For the 1992 taxable year, respondent concedes (1) that
petitioner's income for 1992 does not include $177,726 deposited
in his SUB account, and (2) that the unreported income from
petitioner's deposits in the FIB Roseburg account is $18,157 as
set forth in the bank deposits method rather than the $18,313
determined in the notice of deficiency. On the basis of
respondent's concessions and petitioner's failure to show that
any of the deposits were not income, we find petitioner failed to
report $53,330 of gross receipts in 1992 ($35,173 from the main
account and $18,157 from the FIB Roseburg account).
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