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expenditure. See Bevan v. Commissioner, T.C. Memo. 1971-312,
affd. 472 F.2d 1381 (6th Cir. 1973); see also Reed v.
Commissioner, T.C. Memo. 1997-388, affd. without published
opinion 155 F.3d 560 (4th Cir. 1998).
Blohm v. Commissioner, 994 F.2d 1542 (11th Cir. 1993), affg.
T.C. Memo. 1991-636, is a decision of the Court of Appeals for
the Eleventh Circuit, which, if it were squarely on point, we
would be bound to follow under the Golsen doctrine. In Blohm,
the Court of Appeals said: “For the presumption [of correctness]
to adhere in cases involving the receipt of unreported income,
however, the deficiency determination must be supported by some
evidentiary foundation linking the taxpayer to the alleged
income-producing activity.” Blohm v. Commissioner, 994 F.2d at
1549 (internal quotation marks omitted). Blohm is
distinguishable for the same reason that Llorente v.
Commissioner, supra, would be distinguishable were this case
appealable to the Court of Appeals for the Second Circuit; viz,
we are here dealing with cash deposits and expenditures, which is
prima facie evidence of income.
Petitioner bears the burden of proof.
4. 1992 Adjustment
Respondent adjusted petitioner’s 1992 gross income on
account of the NCNB deposit ($25,000 deposited into an account of
petitioner’s on February 10, 1992). In the petition, petitioner
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