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been double counted in respondent’s bank deposits analysis. The
check was not timely exchanged with respondent, and the back of
the check was not offered into evidence. Without the back of the
check, it was impossible to determine to which account the check
had been deposited. Petitioner failed to establish that the
check represents a deposit that was treated by respondent as
coming from a taxable source.
Instead of providing evidence of a nontaxable source for the
deposits respondent identified in his bank deposits analysis,
Carroll attempted to offer an alternative bank deposits analysis.
In preparing her bank deposits analysis, Carroll assumed that all
income from a taxable source was deposited into the Medicine
International Account or one of petitioner’s J.G. Edwards
accounts. Carroll testified that her assumption was based on
assurances from petitioner. Carroll admitted that she could not
specifically identify where the deposits came from.
In this case, we do not accept petitioner’s unsworn, self-
serving statements to Carroll, upon which she based her analysis,
as credible. Petitioner intentionally created a confusing web of
bank accounts in his own name, in the names of his eight trusts,
and in the name of his current spouse, and engaged in numerous
interaccount transfers. Petitioner failed to maintain a proper
accounting system to keep track of these transactions and has
been unable to explain with documentary evidence the sources of
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