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the contrary, as we have found, the $28,072 paid by Stanford
University in 1991 to California Barbecue is properly taxable to
petitioner as an individual.
2. Bank Deposits Analysis
Respondent, in an amendment to his answer, asserts increased
deficiencies based upon deposits made into bank accounts
maintained in petitioner’s name and Social Security number.
Because respondent first asserted the increases in deficiency in
an amendment to the answer, respondent bears the burden of proof
as to those increases. See Rule 142(a).
Bank deposits are prima facie evidence of income. See
Tokarski v. Commissioner, 87 T.C. at 77. In demonstrating the
existence of income under the bank deposits method, the
Commissioner is not required to show a likely source of that
income. See Clayton v. Commissioner, 102 T.C. 632, 645 (1994).
The bank deposits method assumes that all money deposited in a
taxpayer's bank account during a given period constitutes taxable
income, although the Commissioner must take into account any
nontaxable source or deductible expense of which the Commissioner
has knowledge. See id.; DiLeo v. Commissioner, 96 T.C. at 868.
In this case, respondent has met his burden of proof as to
income under the bank deposits method. Respondent produced
records from two Great Western Bank accounts, Nos. 308-8083971
and 308-8064948, maintained by petitioner. The first used the
name "Warren R. Ketler, D.B.A. Thru The Lens" and employed
petitioner's Social Security number and address. The second was
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