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1990, and 1991, respectively. Subsequently, respondent conceded
$7,400 of the $15,499 unreported gross receipts adjustment for
1990 and $5,080 of the $22,410 unreported gross receipts
adjustment for 1991.
It is well established that respondent may utilize indirect
methods of reconstructing a taxpayer’s income. Where a taxpayer
fails to provide adequate records, an indirect method may be used
to reconstruct income. See Holland v. United States, 348 U.S.
121 (1954). Respondent used the bank deposits method to
reconstruct petitioner’s income. The bank deposits method has
been approved as an indirect method with which to reconstruct
income. See United States v. Carter, 721 F.2d 1514, 1538 (11th
Cir. 1984) (citing United States v. Boulet, 577 F.2d 1165 (5th
Cir. 1978)); Holland v. United States, supra. Petitioner must
show by a preponderance of the evidence that respondent’s
determination is erroneous. See Rule 142(a); Welch v. Helvering,
290 U.S. 111 (1933); Webb v. Commissioner, 394 F.2d 366, 372 (5th
Cir. 1968), affg. T.C. Memo. 1966-81.
Petitioner did not offer records of her law practice or a
methodology that would more clearly reflect income than the bank
deposits reconstruction used by respondent. In addition,
petitioner does not question respondent’s approach or methodology
in reconstructing her income by means of the bank deposits
method. Instead, she contends that some of the deposits that
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