Adell Maxie, Jr. - Page 6




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                    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 into                                                                                         





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