Page:T.C. Memo. 2012-281.pdf/29

[*29] issue and identified deposits that were not taxable. Respondent has properly reconstructed petitioner’s income using the bank deposits method for the years at issue. Accordingly, the burden of proof falls on petitioner to demonstrate that respondent’s determinations are arbitrary or erroneous. B. Petitioner’s Arguments Petitioner does not assign error to respondent’s use of the bank deposits method or respondent’s reconstruction of income. Petitioner contends only that respondent may not assign the unreported income to her because the unreported income is attributable entirely to Mr. Hovind. Although her argument is not entirely clear, petitioner appears to argue that the doctrine of collateral estoppel precludes respondent from relitigating the issue of whether she may be assigned any of the unreported income from CSE because courts in prior cases have held that Mr. Hovind alone is responsible for CSE’s income. Petitioner also contends that she neither earned nor was responsible for the unreported income and therefore respondent acted erroneously in attributing the unreported income to petitioner. We address each of petitioner’s arguments below. ___________