- 78 - 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 jointPage: Previous 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 Next
Last modified: May 25, 2011