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show that the determination is incorrect. See Rule 142(a); Welch
v. Helvering, 290 U.S. 111, 115 (1933).
In calculating petitioner’s 1992 income using the bank
deposits method, Agent Harkins found several items that were not
reported on petitioner’s income tax return. In particular, it
was determined that deposits from McDevitt & Street totaling
$39,500 and deposits from Floyd & Lloyd totaling $17,287 were not
reported as income. Petitioner admits receiving the income and
contends that the income from McDevitt & Street was included in
“Other Income” on its tax return, and the income from Floyd &
Lloyd was included in “Rental Income” on its tax return.
Respondent, however, reviewed petitioner’s “Other Income”
and “Rental Income” accounts and determined that the income from
McDevitt & Street and Floyd & Lloyd was not included in any of
those accounts. Accordingly, respondent has specifically
identified items of income that were not included on petitioner’s
1992 corporate tax return. Petitioner, at trial, introduced a
new analysis of deposits in an attempt to show that the
questioned 1992 income items were reported and that petitioner’s
reported 1992 income was overstated by a few thousand dollars.
The 1992 schedule presented by petitioner at trial was not the
same schedule that had been presented to Agent Harkins during the
audit examination, and it did not reconcile to petitioner’s books
of account. Petitioner’s analysis presented at trial,
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