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claimed inaccuracy in respondent's calculations. See id. at
1294; Webb v. Commissioner, 394 F.2d 366, 372 (5th Cir. 1968),
affg. T.C. Memo. 1966-81; DiLeo v. Commissioner, 96 T.C. 858, 871
(1991), affd. 959 F.2d 16 (2d Cir. 1992); Harper v. Commissioner,
54 T.C. 1121, 1129 (1970). The reconstruction of income need
only be reasonable in light of all surrounding facts and
circumstances. See Giddio v. Commissioner, 54 T.C. 1530, 1533
(1970); Schroeder v. Commissioner, 40 T.C. 30, 33 (1963). For
1992 and 1993, respondent determined petitioners' income using
the bank deposits method. In 1994 and 1995, respondent
determined petitioners' income using the cash expenditures
method.
1. Bank Deposits Analysis
In general, the bank deposits method reconstructs a
taxpayer's income by analyzing deposits and withdrawals from a
taxpayer's bank account. See Dodge v. Commissioner, 96 T.C. 172,
181 (1991), affd. in part and revd. in part on another ground and
remanded 981 F.2d 350 (8th Cir. 1992). Bank deposits are prima
facie evidence of income, and the Commissioner need not show a
likely source of that income. See Tokarski v. Commissioner, 87
T.C. 74, 77 (1986); Estate of Mason v. Commissioner, 64 T.C. 651,
656-657 (1975), affd. 566 F.2d 2 (6th Cir. 1977). When the bank
deposits method is employed, however, the Commissioner must take
into account any nontaxable source or deductible expense of which
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