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amount of income that the taxpayer has failed to report applying
the Cohan principle); Smith v. Commissioner, T.C. Memo. 1993-548.
Even given respondent's burden of proof with respect a portion of
the amount at issue, we think any further adjustment would be
unguided and unwarranted judicial largess. Williams v. United
States, 245 F.2d 559, 560 (5th Cir. 1957).
C. Total Deposits
Respondent also asserted an increased deficiency based on an
increase in the amount of total bank deposits from $42,964 to
$44,766.
At trial, respondent produced copies of petitioners' bank
statements, and we are convinced that petitioners' total deposits
for 1992 totaled $44,766. Contrary to petitioners' contention,
petitioners' bank statements reflect that respondent did not take
into account any cash advances from petitioners' cash reserve
account to arrive at the $44,766 total deposit figure. Thus,
respondent has satisfied the burden of proof in this regard. See
Rule 142(a).
In view of the foregoing, we conclude that petitioners
received $14,191 of unreported self-employment income.6
Issue (2) Schedule C Deductions
Deductions are a matter of legislative grace, and the
taxpayer bears the burden of proving that he or she is entitled
6 We note that this amount is in addition to the $14,180 of
unreported self-employment income the receipt of which
petitioners have already conceded.
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