- 8 - T.C. 858, 867 (1991), affd. 959 F.2d 16 (2d Cir. 1992). Particularly where taxpayers fail to keep adequate records, bank deposits constitute prima facie evidence of income. Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). For 1992, petitioners do not contest respondent’s bank deposits calculation of DUI’s gross income. For 1993, petitioners argue that $16,669 of the $18,232 unreported income of DUI as calculated by respondent represents additional nontaxable interbank transfers for which petitioners should be given credit. Petitioner testified generally that the standard practice of DUI was to transfer all of the funds received in the form of credit card authorization slips and initially deposited into DUI’s bank account located in Sarasota, Florida, to DUI’s bank account located in Tampa, Florida. Begole testified only that some of DUI’s funds received and deposited represented interbank transfers, and petitioner did not call Johnson or Ligori to testify even though they likely were in the best positions to know the specifics relating to the interbank transfers. Petitioner did not offer sufficient corroborating evidence regarding the alleged additional interbank transfers to the DUI bank account located in Tampa, Florida, and we find petitioner’s testimony unpersuasive. We sustain respondent’s determinations of DUI’s unreported gross income for 1992 and 1993.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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