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respondent's determination that Thomas had capital gain income
which totaled $15,714 and $15,040 in 1993 and 1994, respectively.
Under section 6001, a taxpayer must maintain adequate books
and records of taxable income. In the absence of adequate
records, the Commissioner is authorized to reconstruct a
taxpayer's income by any reasonable method that clearly reflects
income. Sec. 446(b). A bank deposit is prima facie evidence of
income, and the Commissioner does not need to prove a likely
source of that income. Estate of Mason v. Commissioner, 64 T.C.
651, 656-657 (1975), affd. 566 F.2d 2 (6th Cir. 1977); Smith v.
Commissioner, T.C. Memo. 1993-460.
Respondent determined that Thomas had $1,700 of unreported
income in 1993 after an analysis of Thomas' bank deposits.
Thomas claimed that the payments may have been a transfer from
one of his other accounts. The burden of showing duplication is
on the petitioner. Estate of Mason v. Commissioner, supra at
657-659; Zarnow v. Commissioner, 48 T.C. 213, 216 (1967). Thomas
did not provide any records to support his position.
Accordingly, we conclude that Thomas had $1,700 of unreported
income in 1993. Respondent determined that this $1,700 was
Schedule C income. Petitioner did not prove otherwise.
Respondent’s determination is sustained.
Section 162 provides for a deduction for all ordinary and
necessary expenses paid or incurred during the taxable year in
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