- 23 - Because petitioner proved that respondent’s reliance on the 1987 and 1989 financial statements under the circumstances involved in this case was unreasonable and resulted in substantially distorted income adjustments, we conclude that the adjustments to petitioner’s Schedule C income as determined by respondent in the notices of deficiency were arbitrary and excessive. Therefore, the burden of producing credible evidence showing that respondent’s revised adjustments to petitioner’s Schedule C income in each of the years 1987 and 1989 were warranted shifted to respondent. Helvering v. Taylor, supra at 514-515; Commissioner v. Riss, 374 F.2d 161, 166 (8th Cir. 1967), affg. in part, revg. in part and remanding T.C. Memo. 1964-190. Respondent contends that, even if the burden of production shifted to respondent regarding the income adjustments in the notice of deficiency, his revised income adjustments for each of the years 1987 and 1989 are supported by the bank deposits analyses respondent introduced into evidence. According to respondent, those analyses prove that petitioner deposited into her bank accounts substantially more money during 1987 and 1989 than she reported as gross receipts on her Schedules C for those years. The bank deposits method has long been recognized as an acceptable indirect method of proving a taxpayer’s understatement of income. See Gleckman v. United States, 80 F.2d 394 (8th Cir.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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