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long been sanctioned by this Court. See DiLeo v. Commissioner,
96 T.C. 858, 867 (1991), affd. 959 F.2d 16 (2d Cir. 1992); Estate
of Mason v. Commissioner, 64 T.C. 651 (1975), affd. 566 F.2d 2
(6th Cir. 1977). The bank deposit method assumes all money
deposited into a taxpayer's bank account during a given period is
income. See DiLeo v. Commissioner, supra at 868. Bank deposits
are prima facie evidence of income. See Tokarski v.
Commissioner, 87 T.C. 74, 77 (1986); Estate of Mason v.
Commissioner, supra at 656. In analyzing a bank deposits case,
deposits are considered income when there is no evidence that
they represent anything other than income. See Price v. United
States, 335 F.2d 671, 677 (5th Cir. 1964); United States v.
Doyle, 234 F.2d 788, 793 (7th Cir. 1956).
The record consists of the business ledger and a few random
Donut Star checks payable to Seafirst Bank and the Internal
Revenue Service. Mr. Ngo has not provided bank statements, cash
register receipts, or any testimony to support his position that
the original claimed gross receipts are correct.
After review of the record, we find that Mr. Ngo failed to
prove the gross receipts of Donut Star, and, therefore,
respondent’s determination is sustained for all years at issue.
Schedule C Expense Deductions
Deductions are a matter of legislative grace, and taxpayers
bear the burden of proving the entitlement to any deduction
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