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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 Klein
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