-7-
Section 28 Limited Partnership in the amount of $214. Respondent
also disallowed $28,048 of petitioner’s itemized deductions.6
For the year 2001, respondent determined that petitioner
received but did not report a partnership distribution from the
Section 28 Limited Partnership in the amount of $683.
Respondent’s bank deposits analysis showed that petitioner
received $19,233 of additional unreported income.7 Respondent
also disallowed $14,963 of petitioner’s itemized deductions and a
Schedule E rental expense deduction of $810.8
For the year 2002, respondent determined that petitioner
failed to report the following specific items of income: (1) A
partnership distribution of $951 from the Section 28 Limited
Partnership; (2) Social Security benefits of $1,571; and (3) a
gross dividend from Cetus Healthcare Limited Partnership II of
$124. Respondent determined that petitioner had additional
income based on bank deposits of 11,491,9 and increased
6Respondent denied or reduced petitioner’s claimed home
mortgage interest deduction under sec. 163, charitable
contribution deduction under sec. 170, deduction for taxes paid
under sec. 164, and deductions for unreimbursed employee expenses
for vehicle, travel, and other employee business expenses.
7During the year 2001, petitioner made net deposits of
$75,496 into his bank accounts, while he reported only $56,262 of
income on his return.
8The disallowed deductions included deductions for State and
local taxes, interest expense, charitable contributions, and
employee business expenses.
9The deposits were of cash and a certified check drawn on
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