- 5 -- 5 - required to maintain records sufficient to establish the amount of his or her income. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs. In the absence of adequate books and records, the Commissioner may reconstruct a taxpayer’s income by any reasonable method. See sec. 446(b); Holland v. United States, 348 U.S. 121 (1954). The bank deposits method has long been recognized as a reasonable method to reconstruct income where the taxpayer’s records are inaccurate or incomplete. See Estate of Mason v. Commissioner, 64 T.C. 651, 656 (1975), affd. 566 F.2d 2 (6th Cir. 1977). “Though not conclusive, bank deposits are prima facie evidence of income.” Id. In an attempt to explain the discrepancy between the gross receipts reported and his bank deposits for the year at issue, petitioner testified that he transferred funds from savings accounts and deposited funds received from loans that he previously had made. However, petitioner presented absolutely no evidence to corroborate his testimony. It is well settled that we are not required to accept a taxpayer’s self-serving testimony in the absence of corroborating evidence. Niedringhaus v. Commissioner, 99 T.C. 202, 212 (1992). We find the testimony given by petitioner to be too vague and based too much upon conjecture to establish that the bank deposits totaling $9,363 relate to transfers and loans. No evidence in the record establishes that the deposits made intoPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011