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cashier’s checks.
On the record before us, we find that, as required by
section 7522(a), the notices describe the basis for respondent’s
determination to increase petitioner’s gross receipts for each of
the years at issue. The bank deposits method that respondent
used in order to determine whether petitioner had unreported
gross receipts for each of those years assumes that all money
deposited into a taxpayer’s bank account during a given period
constitutes taxable income, although the Commissioner must take
into account any nontaxable source or deductible expense of which
the Commissioner has knowledge. Clayton v. Commissioner, 102
T.C. 632, 645-646 (1994); DiLeo v. Commissioner, 96 T.C. 858, 868
(1991), affd. 959 F.2d 16 (2d Cir. 1992). Thus, bank deposits
are prima facie evidence of income. Clayton v. Commissioner,
supra at 645. The taxpayer has the burden of proving that the
bank deposits were derived from nontaxable sources, see id., or
constitute income that he previously reported, see Calhoun v.
United States, 591 F.2d 1243, 1245 (9th Cir. 1978); Nicholas v.
Commissioner, 70 T.C. 1057, 1064 (1978). Respondent is not
required to prove a likely source of a taxpayer’s bank deposits.
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).
In support of respondent’s determinations in the notices
that remain at issue with respect to petitioner’s Schedule C
gross receipts for 1991, 1992, and 1993, respondent is not
relying on a basis or a theory that is not described in the
notices. Respondent relied in the notices, at trial, and at
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