- 8 - compute the taxpayer's income by any method that clearly reflects income. Meneguzzo v. Commissioner, 43 T.C. 824, 831 (1965). A bank deposits analysis has been accepted by the Courts as satisfying this legislative mandate. Harper v. Commissioner, 54 T.C. 1121, 1129 (1970); Pao v. Commissioner, T.C. Memo. 1984-224. The Commissioner's determination of tax liability, when calculated under a bank deposits analysis, is presumptively correct and places upon the taxpayer the burden of proving the determination wrong. Helvering v. Taylor, 293 U.S. 507 (1935); Kearns v. Commissioner, 979 F.2d 1176, 1178 (6th Cir. 1992), affg. T.C. Memo. 1991-320; Traficant v. Commissioner, 884 F.2d 258, 263 (6th Cir. 1989), affg. 89 T.C. 501 (1987); Calderone v. United States, 799 F.2d 254, 258 (6th Cir. 1986). A bank deposits analysis requires that all deposits in the bank be totaled and that adjustments be made to eliminate deposits that reflect nontaxable items such as gifts and loans. A taxpayer's bank deposits, absent an explanation, are considered taxable income. Sindik v. Commissioner, T.C. Memo. 1996-47. Petitioner asserts that the unexplained deposits are nontaxable income. According to petitioner, those deposits are primarily the proceeds of loans which he received from financial institutions, friends, and family. We are unpersuaded that this is so. On the basis of our review of respondent’s analysis, in the light of the record as a whole, we sustain respondent’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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