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Cosmetics Co., in which she sold the beauty products of that
company. Petitioner had been engaged in this activity for
approximately 10 years. Wilson R. Collins was employed by a
private security firm during the years at issue. In addition to
petitioner's Mary Kay Cosmetics activity, petitioners owned an
apartment building during the years at issue. On their Federal
income tax returns, petitioners reported their income and
expenses from the Mary Kay Cosmetics activity and the apartment
building rental activity on Schedules C and E, respectively,
Profit or Loss From Business, and Supplemental Income and Loss.
The determinations of the Commissioner in a notice of
deficiency are presumed correct, and the burden is on the
taxpayer to show that the determinations are in error. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Further,
section 6001 requires, in pertinent part, that "Every person
liable for any tax * * * shall keep such records, render such
statements, make such returns, and comply with such rules and
regulations as the Secretary may from time to time prescribe."
Section 1.6001-1(a), Income Tax Regs., provides, in pertinent
part, that "any person subject to tax under subtitle A of the
Code * * *, shall keep such permanent books of account or
records, including inventories, as are sufficient to establish
the amount of gross income, deductions, credits, or other matters
required to be shown by such person in any return of such tax".
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