- 33 - Respondent used the bank deposits method to identify two sources of unreported income. The first source was determined from checks written from the corporate bank accounts of petitioners’ business entities and deposited into petitioners’ personal bank accounts. The second source was determined from deposits of unexplained amounts of cash and checks from sources other than petitioners’ business entities or those reported on petitioners’ income tax returns into petitioners’ personal bank accounts. Respondent submitted into evidence copies of the bank records that disclosed all of the deposits to as well as the disbursements from petitioners’ personal bank accounts during the years in issue. Respondent analyzed these bank records and prepared schedules that summarized the deposits to, disbursements from, and other transactions occurring in petitioners’ personal bank accounts during those years. Respondent identified deposits that were not taxable or that were previously reported by petitioners. Consequently, respondent has properly reconstructed petitioners’ income under the bank deposits method for the years in issue. If the taxpayer contends that the Commissioner’s use of the bank deposits method is unfair or inaccurate, the burden is on the taxpayer to show such unfairness or inaccuracy. Price v. United States, supra at 677. Petitioners must show either that respondent’s computation of their income is inaccurate or thatPage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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