- 18 - 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 thatPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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