- 25 - $4,21313 to arrive at petitioner’s 1989 reported Schedule C gross receipts of $124,463. Respondent arbitrarily used entries from the 1987 and 1989 financial statements to substantially increase petitioner’s Schedule C income in the notices of deficiency. When respondent recognized the inherent weakness of his position, respondent attempted to salvage his position that income adjustments were warranted by arranging for the preparation of what purported to be bank deposits analyses. The analyses, however, failed adequately to adjust for nontaxable items, failed to analyze all of petitioner’s bank accounts, and failed to adjust for all of petitioner’s reported taxable income. Respondent did not obtain and review all of petitioner’s bank records, including copies of deposited items, and it is apparent from a review of the analyses that respondent did not obtain the information necessary to prepare a proper bank deposits analysis for either 1987 or 1989. A review of respondent’s bank deposits analysis for 1987, which was similar in method to the one for 1989, illustrates why we assign no credibility to respondent’s bank deposits analyses and related income determinations for 1987 and 1989. The 1987 bank deposits analysis is an analysis of one of petitioner’s bank accounts that she used during that year. ANB account No. 302- 13Respondent has conceded that client refunds of $4,213.30 are deductible.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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