KENNEDY, Circuit Judge:
The Tax Court affirmed the IRS's determination that $43,000 in Swiss gold coins and $305 in unexplained bank deposits constituted unreported income. The Delaneys now appeal, challenging the assessment of a deficiency and a negligence penalty pursuant to 26 U.S.C. § 6653(a). We affirm.
The Commissioner's deficiency determination is entitled to a presumption of correctness "once some substantive evidence is introduced demonstrating...
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