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to computer purchases. Petitioner offered no evidence to put in
doubt the correctness of respondent’s determinations.
Finally, respondent established that petitioner received
additional unreported income that was not deposited to
petitioner’s or PAC’s bank accounts. A number of PAC’s
customers, in response to Agent Bricker’s mailing, provided
evidence of additional computer purchases from PAC, the income
from which was not recognized on PAC’s or petitioner’s tax
returns and was not traceable to petitioner’s or PAC’s bank
accounts. Many of these were cash sales. Petitioner received
additional unreported income of $37,733.38 for 1988, $20,319.27
for 1989, and $16,417.87 in 1990 on account of these unrecorded
sales.
In sum, Agent Oertel established that petitioner received
and failed to report income of $220,198.54 for the 3 years in
issue, consisting of $96,531.828 in 1988, $56,410.969 in 1989,
8This consists of $48,956.84 identified using the deposit
method from responses to Agent Bricker’s mailing, $9,841.60
identified using the deposit method from indicia on the checks,
and $37,733.38 identified from the specific evidence provided by
PAC customers in response to Agent Bricker’s mailing.
9This consists of $30,586.19 identified using the deposit
method from responses to Agent Bricker’s mailing, $5,505.50
identified using the deposit method from indicia on the checks,
and $20,319.27 identified from the specific evidence provided by
PAC customers in response to Agent Bricker’s mailing.
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