-23- and the Commissioner has determined that the deposits are income, the burden is on the taxpayer to show that the Commissioner’s determination is incorrect. Petitioners argue that respondent’s use of the bank deposits analyses was unjustified because, they state, they kept adequate records establishing their income. We disagree. While petitioners may have used a computer program to memorialize their income and expenses, we are unable to find from credible evidence in the record that petitioners ever gave to respondent, before issuance of the notices of deficiency, adequate records to support their reported income for any subject year. On the basis of the record at hand, we hold that respondent’s use of the bank deposits analyses was proper. Petitioners argue alternatively that respondent misapplied the bank deposits analyses in that, they argue, respondent failed to recognize that most of the disputed deposits arose from nontaxable sources. Petitioners argue that respondent’s bank deposits analyses should be adjusted as follows: 1997 Petitioners’ As Additional As Determined Adjustments Adjusted Total deposits (including interest) $1,087,054 -0- $1,087,054.00 Less adjustments: Interaccount transfers 293,008 $15,599.29 308,607.29 Loan receipts 22,600 -0- 22,600.00 Loan repayments -0- 35,000.00 35,000.00 VISA advances 21,750 2,500.00 24,250.00 Sales tax remittances 32,255 3,800.00 36,055.00 Returned deposits 1,387 -0- 1,387.00 Expense report reimbursement -0- 6,414.04 6,414.04 Total 371,000 63,313.33 434,313.33Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: November 10, 2007