- 9 - use of the bank deposits method to reconstruct his income for 1996 and 1997. Petitioner contends that he had the following nontaxable sources of income: Loans from his friends, brothers, or sister of $1,600 on March 5, 1996, $4,500 on April 24, 1997, $3,800 on June 18, 1997, $3,000 on June 20, 1997, and $3,000 on July 1, 1997.5 We disagree. Petitioner has no promissory notes or records showing that these amounts were loans or that he repaid them. He did not identify specific individuals who lent him these amounts. Petitioner’s testimony that these deposits were loans was vague and uncorroborated. We are not convinced that the source of any of the bank deposits respondent counted as unreported income for petitioner in 1996 and 1997 was a nontaxable loan. We conclude that petitioner had unreported income of $64,108.94 in 1996 and $21,942.75 in 1997. C. Whether Petitioner May Deduct More Business Expenses Than Respondent Allowed for 1996 and 1997 Petitioner deducted more miscellaneous expenses related to his Schedule C business than respondent allowed for 1996 and 5 Petitioner’s contention on brief differs slightly from his contention at trial. On brief, he contended that deposits in his bank accounts “that are large and end in ‘000', such as $1,000.00, $3,000.00, and $5,000.00, are loan funds I received from my family and friends.” At trial, he contended that bank deposits of $1,000 or more were funds which were lent to him by friends and family and then identified the five specific deposits (shown above) as loans. He did not show that any of the deposits respondent used to determine unreported income were loans.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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