Kamil F. and Nagwa Gowni - Page 33

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               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 that              






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