- 22 - of those reductions of petitioners' bank deposits for the years at issue.5 However, petitioners contend that for each year at issue the excess of (1) petitioners' bank deposits reduced by those amounts attributable to nontaxable sources that respondent allowed over (2) the amount of total income that petitioners reported in their return for each such year also is attributable to a nontaxable source, namely, a cash hoard. Respondent may disprove petitioners' allegation of a cash hoard by showing that respondent's reconstruction of income under the bank deposits method is accurate and that petitioners' allegation of a cash hoard is inconsistent, implausible, and not supported by objective evidence in the record. See Parks v. Commissioner, supra. On the record before us, we find that respondent's reconstruction of petitioners' income under the bank deposits method, as alleged as part of respondent's alternative position in the answer, is accurate. Indeed, the only complaint 4 (...continued) on the notice, respondent reduced petitioners' total deposits for the years at issue in amounts of such deposits that were greater than those allowed under respondent's alternative position in the answer. 5 Respondent also adjusted the total income of Paul & Joe, Inc., (1) for 1993 in the amounts of $14,515 for corporate purchases paid for by Mr. Mifsud and $2,000 for checks deposited to that business for cash and (2) for 1994 in the amounts of $11,946 for corporate purchases paid for by Mr. Mifsud and $7,691 for checks deposited to that business for cash. Petitioners do not dispute those adjustments.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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