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they deducted on their 2001 return. Petitioner did not
substantiate any of those deductions. Some of the amount
petitioner deducted as unreimbursed employee expenses was job
hunting expenses. The examiner did not attribute any income to
them on the basis of deposits in the account of TAIS, Inc.
OPINION
A. Whether Petitioner Had Gross Income in the Amounts
Respondent Determined for 1998, 2000, and 2001
Petitioner contends that respondent overstated the amounts
of petitioner’s unreported gross income for 1998, 2000, and 2001.
We disagree.
If a taxpayer does not maintain adequate books and records,
the Commissioner may reconstruct the taxpayer’s income by any
reasonable method which clearly reflects income, sec. 446(b);
Holland v. United States, 348 U.S. 121, 130-132 (1954), including
the bank deposits method, Parks v. Commissioner, 94 T.C. 654, 658
(1990); Estate of Mason v. Commissioner, 64 T.C. 651, 656 (1975),
affd. 566 F.2d 2 (6th Cir. 1977). Bank deposits are prima facie
evidence of income. Tokarski v. Commissioner, 87 T.C. 74, 77
(1986); Estate of Mason v. Commissioner, supra at 656-657.
Petitioner did not keep adequate books and records for the years
in issue. The examiner used the bank deposits method to estimate
petitioner’s gross income for those years.
Petitioner contends that the examiner incorrectly counted
his transfers of funds from one account to another in 1998, 2000,
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