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Bank; these checks represent mortgage payments by petitioner.
Most of the remaining checks were written to petitioner himself or
to Wells Fargo, presumably indicating that on some occasions
petitioner was withdrawing cash from his account. There is no
evidence that any such withdrawal was redeposited into
petitioner’s account. To the contrary, there is evidence that at
least a portion of such funds was used to make payments on a line
of credit or another loan. In summary, we find that the Wells
Fargo checks do not refute any aspect of respondent’s calculation
of petitioner’s unreported income.
Other than the two general arguments discussed above,
petitioner has not presented any specific objections to
respondent’s reconstruction of petitioner’s income. For example,
petitioner has not argued that any individual deposit is from a
nontaxable source, nor has petitioner asserted, or provided
evidence tending to show, that any deposit was from an alternative
source, such as a savings account.
Finally, petitioner summarizes his argument that respondent’s
determinations are in error by stating:
I think that there is clear evidence of the fact that there
is a certain amount of necessary recycling of this money for
the reasons that I have explained to the points that there’s
no way that anybody could say that this clearly reflects
income.
We disagree with petitioner. While respondent’s reconstruction of
petitioner’s records certainly is not exact, we find the
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