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unreported Schedule C gross receipts for each of the years at
issue by reconstructing such gross receipts for each of those
years pursuant to the bank deposits method. In reconstructing
petitioner’s income for each of the years at issue, respondent
added to the results produced by respondent’s bank deposit
analysis certain additional amounts, such as the amounts that
petitioner received when he cashed, and did not deposit, in whole
or in part certain checks or when he used certain checks to
purchase certain cashier’s checks.
We address first what we understand to be petitioner’s
contention that respondent’s bank deposits analysis for each of
the years at issue is inherently flawed. In support of that
contention, petitioner points out that respondent has conceded as
nontaxable certain deposits into petitioner’s accounts during
each of those years, including certain payments against the
balances due on petitioner’s credit accounts during each such
year, which respondent had determined in the notices to be
taxable.
On the record before us, we find respondent’s bank deposits
analysis for each of the years at issue to be reasonable.
Although respondent was required in performing respondent’s bank
deposits analysis for each of those years to take into account
any nontaxable source or deductible expense of which respondent
had knowledge, Clayton v. Commissioner, 102 T.C. at 645-646;
DiLeo v. Commissioner, 96 T.C. at 868, petitioner was generally
uncooperative during the course of the examination of the joint
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