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$1,000 or more as income. Petitioner did not have adequate books
and records. If a taxpayer does not maintain adequate books and
records, the Commissioner may reconstruct a taxpayer's income by
any reasonable method which clearly reflects income, sec. 446(b);
Holland v. United States, 348 U.S. 121, 130-132 (1954), including
the bank deposits method, Parks v. Commissioner, 94 T.C. 654, 658
(1990); Estate of Mason v. Commissioner, 64 T.C. 651, 656 (1975),
affd. 566 F.2d 2 (6th Cir. 1977). Bank deposits are prima facie
evidence of income. Clayton v. Commissioner, 102 T.C. 632, 645
(1994); Tokarski v. Commissioner, 87 T.C. 74, 77 (1986); Estate
of Mason v. Commissioner, supra. If the taxpayer suggests a
nontaxable source, the Commissioner must either connect the bank
deposits to a likely source of taxable income or negate the
nontaxable source alleged by the taxpayer. Kramer v.
Commissioner, 389 F.2d 236, 239 (7th Cir. 1968), affg. T.C. Memo.
1966-234. Respondent has connected the bank deposits to a likely
source of taxable income because petitioner admits that she
deposited gambling winnings in her bank accounts. We conclude
that respondent properly reconstructed petitioner’s additional
income for 1993 and 1994 using the modified bank deposits method.
Thus, petitioner bears the burden of proving that the deposits
were not taxable income to her but were instead derived from a
nontaxable source. Welch v. Commissioner, 204 F.3d 1228, 1230
(9th Cir. 2000), affg. T.C. Memo. 1998-121; Calhoun v. United
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