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by payors who respondent could not identify from the information
provided by petitioner’s bank.
Given the percentage of responses to Agent Bricker’s letter
that showed unreported income from the sale of computer products
and services (82 percent of those who responded stated that their
payment was for PAC computer equipment and services, and none of
this revenue was reported on petitioner’s or PAC’s Federal income
tax returns), there is a high probability, amounting to more than
mere suspicion, that a substantial proportion of the unidentified
or unproven deposits also represent unreported taxable income.
Petitioner offered no credible evidence (and maintained no
credible records) as to the source or nature of those deposits.
Although it’s not our job to tell respondent how to do his
job, see United States v. Payner, 447 U.S. 727, 731, 737 (1980)
(Burger, C.J., concurring), we observe that respondent
established substantial amounts of unexplained deposits that were
not included in the deficiency notice.12
We have affirmed determinations of unreported income under
the bank deposits method where the Commissioner has offered no
evidence as to the source of the deposits, requiring the
Commissioner to show only that unexplained deposits were made to
12Our concerns are aggravated by the evidence in the record
that during 2 of the taxable years in issue and the year
following, petitioner purchased four parcels of real property for
$1.925 million, making aggregate downpayments of $755,038. See
supra note 2.
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