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determined in the notice of deficiency to reflect the proof of
additional amounts introduced into evidence at trial: “To the
extent that Revenue Agent Oertel’s analysis exceeds the amounts
asserted in the Statutory Notice of Deficiency for 1988 and 1989,
respondent will not seek an increased deficiency.” In addition,
Agent Oertel identified several items that were double counted in
the notice of deficiency for 1990. For 1990, Agent Oertel’s
analysis shows a lower deficiency of $67,255 than was set forth
in the statutory notice of deficiency of $78,253. In his trial
brief and at trial, respondent conceded the excess: “For 1990,
inasmuch as Revenue Agent Oertel’s analysis shows less unreported
income than the Statutory Notice of Deficiency, respondent has
conceded the excess.” We accept respondent’s concession for
1990.
Respondent’s deficiency determinations excluded substantial
additional amounts of unreported income that are apparent from
the record. Respondent determined the deficiencies using only
the amounts concretely proved to be unreported income on the
basis of his single information request. The evidence suggests
that petitioner received substantial additional amounts of
unreported income. Respondent identified deposits of $769,612
made to petitioner’s bank account for which the drawers of the
checks did not respond to Agent Bricker’s mailing, and an
additional $695,910 in deposits made to petitioner’s bank account
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