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part Mandina v. Commissioner, T.C. Memo. 1982-34. Petitioner
argues, however, that this case presents an exception to the
general rule because the notice of deficiency, at least with
respect to the items here in question, is arbitrary and without
foundation. Petitioner cites Llorente v. Commissioner, 649 F.2d
152 (2d Cir. 1981), affg. in part revg. in part, and remanding 74
T.C. 260 (1980). In Llorente, the Commissioner’s notice of
deficiency was based on his reconstruction of the taxpayer’s
income from drug dealing, and in the view of the Court of Appeals
there was inadequate evidence that the taxpayer had actually
purchased or sold cocaine during the period in issue. In
Tokarski v. Commissioner, 87 T.C. 74 (1986), we distinguished
Llorente (which would have applied under the doctrine of Golsen
v. Commissioner, 54 T.C. 742 (1970), affd. 445 F.2d 985 (10th
Cir. 1971)), on the basis that, in that case (Tokarski), which
involved a bank deposit of $30,000, there was no question that
the taxpayer received that sum: “Under these circumstances, we
hold that there is no requirement that respondent produce
evidence linking petitioner to an income-producing activity as a
precondition to requiring petitioner to meet his burden of
proof.” Tokarski v. Commissioner, 87 T.C. at 76-77 (fn. ref.
omitted). We generalized: “A bank deposit is prima facie
evidence of income and respondent need not prove a likely source
of that income.” Id. at 77. The same holds true for a cash
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