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Tan Credit Union under the name of National Land Bank LLC
(Account No. 8198), respondent effectively connected the deposits
from taxable sources to National Land Bank’s account. Petitioner
introduced no evidence to refute this adjustment.
Respondent’s bank deposit method is an acceptable means to
determine the amount of income received by National Land Bank in
2000. Moreover, Speck in 2000 is treated as a disregarded entity
for Federal tax purposes; therefore, all the income earned by
National Land Bank ($35,200), including Speck’s share, is
attributed to petitioner.
F. Nature’s Herb & Tea Garden Income
Petitioner refused to confirm or deny that she maintained
the business, Nature’s Herb & Tea Garden. Respondent provided
bank records showing checks payable to Nature’s Herb & Tea Garden
deposited into an account at Norwest Bank Arizona, N.A. in the
name of “Sue Taylor d|b|a Natures Herb & Tea Garden”. The
uncontroverted evidence of bank deposits being made to the
account controlled by petitioner is sufficient to link petitioner
to the income from Nature’s Herb & Tea Garden. Because
petitioner offered no evidence regarding her association with
Nature’s Herb & Tea Garden, she has failed to rebut the
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