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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’s
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