Ragnhild A. Westby - Page 24

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          1935); see also United States v. Abodeely, 801 F.2d 1020, 1023-             
          1025 (8th Cir. 1986); Caulfield v. Commissioner, T.C. Memo. 1993-           
          423, affd. 33 F.3d 991 (8th Cir. 1994).  The bank deposits method           
          is often used in cases in which the taxpayer maintained                     
          inadequate, incomplete, or unclear records.  See, e.g., Holland             
          v. United States, 348 U.S. 121 (1954); DiLeo v. Commissioner, 96            
          T.C. 858, 867 (1991), affd. 959 F.2d 16 (2d Cir. 1992); Estate of           
          Mason v. Commissioner, 64 T.C. 651, 656 (1975), affd. 566 F.2d 2            
          (6th Cir. 1977).                                                            
               In this case, petitioner produced records of her taxable               
          income, including her Schedule C income.  The records included              
          handwritten ledger books as well as bank records such as bank               
          statements and deposit tickets.  A review of petitioner’s income            
          records establishes to the Court’s satisfaction that the gross              
          income reported on petitioner’s Schedules C for 1987 and 1989 was           
          derived from petitioner’s handwritten ledger books and was not              
          calculated based on deposits into petitioner’s bank accounts.               
          The return preparer, Mr. Aunan, took the gross receipts numbers             
          that petitioner derived from her ledger books for the years at              
          issue and adjusted the numbers for any refunds made to                      
          petitioner’s clients during the taxable years.  In 1987 Mr. Aunan           
          made no adjustments to petitioner’s Schedule C gross receipts of            
          $75,097, but, in 1989, Mr. Aunan reduced the preliminary gross              
          receipts figure of $129,146 by client refunds of $470 and                   






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