George Maciel - Page 28

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               Less: Nonincome Items Deposited                                        
               Nontaxable deposits2    (328,286.83)   (74,180.81)  (407,639.68)       
               Boscell rents                                                          
               allocable to                                                           
               Viviano             (49,200.00)   (22,250.00)           --             
                              (377,486.83)   (96,430.81)  (407,639.68)                
               Taxable deposits                 380,270.95    356,707.26              
               Less: Deposits Resulting                                               
               From Reported Income                                                   
               Net wages      59,642.28         59,590.17     54,653.28               
               Interest income     16,872.00    16,131.00      6,595.00               
               State tax refund    3,985.00     1,499.00            --                
               Gross rental income     93,423.00125,683.00    140,600.00              
               Other income        6,000.00     –-            --                      
               Total     179,922.28     202,903.17    201,848.28                      
               Additional unreported                                                  
               income          236,147.41     177,367.78    154,858.98                
               1 See appendices A, B, C, D, and E.                                    
               2 See appendix F.                                                      
               In arriving at the above stated figures, respondent used               
          bank records, including deposit slips and checks showing that               
          these amounts were deposited into petitioner’s bank accounts.               
          Generally, petitioner does not dispute these deposits, and                  
          respondent has established, by clear and convincing evidence,               
          that petitioner underreported his income during the taxable years           
          at issue.  However, petitioner claims that he is entitled to                
          adjustments in order to determine taxable income.  Petitioner               
          bears the burden of proof to show any adjustments which would               
          offset unreported income.  Barragan v. Commissioner, T.C. Memo.             
          1993-92, affd. without published opinion 69 F.3d 543 (9th Cir.              
          1995).                                                                      







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