- 7 -
632, 645 (1994); DiLeo v. Commissioner, 96 T.C. 858, 868 (1991),
affd. 959 F.2d 16 (2d Cir. 1992). Therefore, petitioners bear
the burden of proving that they did not receive additional
unreported income in the amount of $11,955.
On the other hand, it is also clear that the Commissioner
bears the burden of proving that the taxpayer is liable for any
increased deficiency asserted by the Commissioner after issuance
of the notice of deficiency. See Rule 142(a); Shaller v.
Commissioner, T.C. Memo. 1984-584, affd. per curiam without
published opinion 813 F.2d 403 (4th Cir. 1986). Thus, respondent
bears the burden of proving the increase in the amount of
unreported income from $11,955 to $16,727 (i.e., the $2,970
decrease in the amount of otherwise taxed deposits and the $1,802
increase in the amount of total deposits).
With these principles in mind, we turn to the matter before
us.
B. Amount of Deposits From Previously Taxed or Nontaxable
Sources
Petitioners contend that respondent's determination is
erroneous because the deposits in question consist of previously
taxed or nontaxable amounts. Specifically, petitioners contend
that the unexplained deposits partially represent a gift in the
amount of $10,000 from Mr. Margolis' mother. Petitioners further
claim that they deposited more than 95 percent of Mrs. Margolis'
self-employment earnings accounting for the remaining unexplained
deposits.
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