-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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: November 10, 2007