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Deficiencies
Petitioner failed to maintain adequate books and records as
required by section 6001. Accordingly, respondent relied on the
net worth method as a means to indirectly reconstruct
petitioner's income for the years in issue. See Holland v.
United States, 348 U.S. 121 (1954); Goodmon v. Commissioner, 761
F.2d 1522, 1524 (11th Cir. 1985); Cupp v. Commissioner, 65 T.C.
68, 82 (1975), affd. without published opinion 559 F.2d 1207 (3d
Cir. 1977). From our examination of respondent's net worth
calculations, we are satisfied that these calculations comport
with the requirements of Holland v. United States, supra. In
particular, respondent made adequate opening cash-on-hand
computations, established a likely source of income, and
investigated relevant leads of nontaxable sources of income. See
id. at 130-131. Respondent's net worth calculations were based
on substantial documentary evidence. Moreover, petitioner has
stipulated or is deemed to have admitted many if not all of the
adjustments underlying respondent's determinations. Petitioner
bears the burden of proving that respondent's determinations are
incorrect. See Parks v. Commissioner, 94 T.C. 654, 658-659
(1990); Schad v. Commissioner, 87 T.C. 609, 620 (1986), affd.
without published opinion 827 F.2d 774 (11th Cir. 1987).
Petitioner failed to offer any credible evidence that
respondent's determinations are erroneous. At trial, petitioner
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