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documents, meetings, and interviews. See also Higbee v. Commissioner, 116 T.C. 438, 440-441 (2001). The taxpayer bears the burden of proving that all of the section 7491(a) requirements have been satisfied. Rolfs v. Commissioner, 135 T.C. 471, 483 (2010), aff’d, 668 F.3d 888 (7th Cir. 2012).

Petitioner contends that the burden of proof should shift to respondent under section 7491(a) because she produced credible evidence and satisfied the requirements of section 7491(a)(2).^[1] We disagree. The record establishes that petitioner did not cooperate with respondent’s reasonable requests and did not maintain the required records. Accordingly, petitioner bears the burden of proof. See Higbee v. Commissioner, 116 T.C. at 440-441.
II. Petitioner’s Income for the Years at Issue
A. Applicability of the Bank Deposits Method

Gross income includes “all income from whatever source derived”. Sec. 61(a). A taxpayer must maintain books and records establishing the amount of his

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perform the function mentioned or described in the context”, sec. 7701(a)(12) (A)(i).

1. In her brief petitioner contends only that she introduced credible evidence and cooperated with all reasonable requests by the Secretary. She does not address whether she complied with the substantiation requirements or maintained all required records.