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accounting does not clearly reflect income, then the method used
shall be the method, which, in the Commissioner’s opinion,
clearly reflects income. Sec. 446(b); see Palmer v. United
States, supra at 1312. Respondent is afforded great latitude in
determining a taxpayer’s liability and is entitled to use any
reasonable method to reconstruct a taxpayer’s income, especially
where a petitioner refuses to cooperate in ascertaining her
income. Petzoldt v. Commissioner, supra; Giddio v. Commissioner,
54 T.C. 1530, 1533 (1970).
Petitioner did not provide any evidence regarding her
liability, and respondent was able to acquire petitioner’s bank
records only by summons. Respondent used the bank deposits
method to determine that petitioner earned the income attributed
to her in the statutory notices of deficiency for 1999 and 2000.
“Where the Commissioner’s method of calculating income is
rationally based, courts afford a presumption of correctness to
the Commissioner’s determination.” Palmer v. United States,
supra at 1312. “The use of the bank deposit method for computing
income has long been sanctioned by the courts.” Estate of Mason
v. Commissioner, 64 T.C. 651, 656 (1975)(and cases cited
thereat), affd. 566 F.2d 2 (6th Cir. 1977). “A bank deposit is
prima facie evidence of income, and respondent need not prove a
likely source of that income.” Tokarski v. Commissioner, 87 T.C.
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