Ragnhild A. Westby - Page 25

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          $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.                                                             





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