- 14 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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