- 13 - Notices of Deficiency Respondent determined petitioner’s gross receipts from his law practice for the 1987, 1988, 1989, and 1990 tax years by using the bank deposits method and by adding various specific items. Specifically, respondent included (1) deposits to the Business Account; (2) certain withdrawals from Trust Account 1 and Trust Account 2; and (3) certain specific items of unreported income that were not deposited to the Business Account, Trust Account 1, or Trust Account 2. Respondent’s analysis showed that, for each of the years, petitioner had substantial deposits in excess of the income that he reported on his return. Respondent issued notices of deficiency to petitioner with respect to his 1987, 1988, 1989, and 1990 tax years. In the notices of deficiency, respondent determined that petitioner had deficiencies in tax for the 1987, 1988, 1989, and 1990 tax years in the amounts of $334,292, $146,963, $39,772, and $224,046, respectively. Respondent also determined additions to tax or penalties for fraud, negligence, and failure to file. OPINION We note at the outset that petitioner did not file a post- trial brief in this case. Rule 151(a) provides, in part, that “Briefs shall be filed after trial or submission of a case, except as otherwise directed by the presiding Judge.” This Court has long recognized the importance of filing a brief. See KleinPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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