-10-
also had unreported income of $19,233.11 The bank deposits
analysis was properly conducted, and represents prima facie
evidence of income. See Tokarski v. Commissioner, 87 T.C. 74, 77
(1986) (citing Estate of Mason v. Commissioner, 64 T.C. 651, 656-
657 (1975) affd. 566 F.2d 2 (6th Cir. 1977)). Respondent
provided petitioner with ample opportunity to present evidence
disputing this income. Petitioner presented no evidence, nor did
he make any credible statements, disputing his receipt of this
income. Furthermore, petitioner testified that he received no
loans, bequests, inheritances, gifts, or other nontaxable amounts
during 2001. We therefore hold that petitioner received
unreported income in the above amounts.
2002
It was deemed admitted under Rule 37(c) that petitioner
understated taxable income by $14,142 and underpaid income tax by
$5,307 for 2002.12 We therefore hold that petitioner received
unreported income in the above amount.
2003
Petitioner failed to file a Federal income tax return for
11The unreported income shown by respondent’s bank deposits
analysis was not deemed admitted under Rule 37(c), nor was it
deemed stipulated under Rule 91(f). This amount, alleged in the
amended answer, increased petitioner’s deficiency from $22,722 to
$28,036; therefore, respondent bears the burden of proof with
respect to this amount. Rule 142(a).
12The amount by which petitioner underpaid his income tax
takes into account disallowed deductions.
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