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the method need only be reasonable in light of all the
surrounding circumstances.
This Court has long accepted the bank deposits method of
income reconstruction. See Nicholas v. Commissioner, 70 T.C.
1057, 1065 (1978); Estate of Mason v. Commissioner, 64 T.C. 651,
653 (1975), affd. 566 F.2d 2 (6th Cir. 1977). While not
conclusive, bank deposits are prima facie evidence of income.
See Boyett v. Commissioner, 204 F.2d 205 (5th Cir. 1953), affg.
T.C. Memo. 1951-67; Hague Estate v. Commissioner, 132 F.2d 775
(2d Cir. 1943), affg. 45 B.T.A. 104 (1941).
Kanter contends that respondent's determination and
reconstruction of his 1982 income under the bank deposits method
was arbitrary and excessive. He claims that he maintained
adequate records (i.e., his check register) identifying the
taxable and nontaxable deposits to his bank accounts. He argues
that respondent's determination should not be accorded its normal
presumption of correctness, and that respondent should either (1)
have the burden of proving that he, in fact, had taxable
deposits, or (2) have the burden of going forward with the
evidence.
Respondent, on the other hand, contends that Kanter did not
meet his burden of proof in establishing that the disputed
deposits had a nontaxable source. Respondent argues that the
evidence Kanter offered is insufficient. Besides the check
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