Koziej, et ux. v. Comr., T.C. Summ. Op. 2010-40

(married couple that failed to report bank deposits in income determined to have taxable income on such amounts; couple failed to show that unreported deposit amounts were nontaxable loans - no corroborating evidence that amounts received from friends were loans and no evidence that couple entered into loan agreements or intended to repay amounts; accuracy-related penalty upheld).