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represented their respective worldwide taxable income for those
years and that all other bank deposits were nontaxable sources of
income and (2) pertained to the matter about which respondent
inquired in respondent’s written interrogatories. Petitioners
did not respond to either the interrogatories or the requests for
production of documents.
On August 11, 2003, respondent filed with the Court in these
cases motions to compel responses to respondent’s interrogatories
and motions to compel production of documents. On August 14,
2003, the Court issued Orders that directed petitioners, in
pertinent part, as follows:
ORDERED: That so much of respondent’s * * *
motions that seeks an order directing compliance with
Respondent’s Interrogatories to Petitioners and
Respondent’s Request for Production of Documents, both
served on July 8, 2003, is granted, and petitioners
shall, on or before September 2, 2003, (1) produce to
counsel for respondent those responses requested in
Respondent’s Interrogatories to Petitioners served on
petitioners on July 8, 2003, and (2) produce to counsel
for respondent those documents requested in
Respondent’s Request for Production of Documents served
on petitioners on July 8, 2003. * * *
Petitioners did not comply with the Court’s Orders.
OPINION
Respondent’s Use of the Bank Deposits Method
Taxpayers bear the responsibility to maintain books and
records that are sufficient to establish their income. See sec.
6001; DiLeo v. Commissioner, 96 T.C. 858, 867 (1991), affd. 959
F.2d 16 (2d Cir. 1992); sec. 1.446-1(a)(4), Income Tax Regs; see
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