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he has knowledge. See DiLeo v. Commissioner, supra at 868.
However, the Commissioner is not required to show that all
deposits constitute taxable income. See Estate of Mason v.
Commissioner, supra at 657; Gemma v. Commissioner, 46 T.C. 821,
833 (1966). Consequently, in analyzing a bank deposits case,
deposits are considered income when there is no evidence that
they represent anything other than income. See Price v. United
States, 335 F.2d 671, 677 (5th Cir. 1964); United States v.
Doyle, 234 F.2d 788, 793 (7th Cir. 1956). The burden of showing
duplications is on the taxpayer. See Zarnow v. Commissioner, 48
T.C. 213, 216 (1967).
On the basis of the deemed admissions, respondent determined
petitioners received $175,258 and $74,895 in income from
landscaping services during 1992 and 1993, respectively. At
trial or on brief petitioners did not question respondent's
determinations of the amount of income earned by them in 1992 and
1993. In addition, petitioners are deemed to have admitted that
they have no documentation substantiating any loans, nontaxable
income, gifts, or inheritances they may have received during 1992
or 1993. Accordingly, petitioners did not meet their burden of
proving that respondent's determinations of petitioners' income
for 1992 and 1993 was erroneous.
In 1992, the income deemed admitted is $220 greater than the
income amount in the notices of deficiency sent to petitioners.
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