- 28 -
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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