- 12 - As concerns the nature of annual reports in general, such reports are derived from the representations of management. And, while financial statements are often verified through audit, to a lesser or greater extent, we have no information as to what, if any, steps were taken to check the proprietorship’s claimed inactivity in 1992 or even as to what exactly was meant by use of the term “inactive” within the context of the annual report. We next turn to the implications of respondent’s bank deposits analysis. In the course of her examination of petitioners’ 1993 return, Ms. Nierich performed a bank deposits analysis in an attempt to verify petitioners’ gross receipts and income. Bank deposits are considered prima facie evidence of income, and a bank deposits analysis typically encompasses the following: (1) A totaling of bank deposits; (2) the elimination from such total of any amounts derived from duplicative transfers or nontaxable sources of which the Commissioner has knowledge; and (3) the further reduction of the adjusted total by any deductible or offsetting expenditures of which the Commissioner is aware. Clayton v. Commissioner, 102 T.C. 632, 645-646 (1994); DiLeo v. Commissioner, 96 T.C. 858, 868 (1991), affd. 959 F.2d 16 (2d Cir. 1992). The burden rests on the taxpayer to prove additional nontaxable sources for deposits and to substantiate greater allowable expenditures. Rule 142(a); Clayton v. Commissioner, supra at 645.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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