-362-
Respondent determined the Kanters failed to maintain or
provide adequate books and records with respect to their taxable
income for 1982. Respondent further determined Kanter had in
excess of $2 million in unreported income for 1982, which
unreported income determination was based upon respondent’s
analysis of deposits to Kanter’s three American National Bank
accounts. The deposit slips from which respondent reconstructed
Kanter’s 1982 taxable income did not specify the taxable or
nontaxable nature of the deposits.144 At trial, Kanter offered
into evidence his check register and a series of spreadsheets and
a summary analysis of his bank deposits prepared by Gallenberger.
Exhs. 9168-9172.
Respondent conceded a portion of the subject adjustment, but
maintains Kanter failed to report $1,303,207 of income for 1982
based on the bank deposits from the payors or sources in the
amounts listed below:
144 The record does not disclose whether the Kanters
provided the check register to the revenue agent who examined
their 1982 return. Apparently the revenue agent had been
unsuccessful in obtaining a number of documents requested from
the Kanters, as the agent attempted to reconstruct Kanter’s 1982
taxable income based upon an analysis of Kanter’s bank account
deposits. To obtain copies of the bank account statements and
other account information, the agent issued a third-party
administrative summons to the bank.
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