Charles A. McGee - Page 13




                                               - 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 Klein                           







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