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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.
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