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any amounts derived from duplicative transfers or nontaxable
sources of which the Commissioner has knowledge; (3) the further
reduction of the adjusted total by any deductible or offsetting
expenditures of which the Commissioner is aware. Clayton v.
Commissioner, supra at 645-646; DiLeo v. Commissioner, supra at
868.
As previously indicated, the burden here rests on petitioner
to show error in respondent’s analysis, either by proving a
nontaxable source for deposits or by substantiating allowable
expenditures. Rule 142(a); Clayton v. Commissioner, supra at
645; Estate of Mason v. Commissioner, 64 T.C. 651, 656-657
(1975), affd. 566 F.2d 2 (6th Cir. 1977). In some circumstances
(e.g., fraud cases), the Commissioner may be expected to
investigate leads of nontaxable sources that are “reasonably
susceptible of being checked.” Holland v. United States, 348
U.S. 121, 135-136 (1954); see also Tunnell v. Commissioner, 74
T.C. 44, 57-58 (1980), affd. 663 F.2d 527 (5th Cir. 1981).
However, this “lead-check rule” has been held inapplicable where
the taxpayer bears the burden of proof or where purported leads
are vague and unsupported by any evidence. Tunnell v.
Commissioner, supra at 57-58.
During 1988, petitioner maintained a single business bank
account in the name of Bicycle Sport at the Dana Niguel Bank. A
second business bank account was opened in the name of Bicycle
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