Albert Dudley Thrower - Page 8

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          taxable period from records of income produced by the activity in           
          question over some shorter period.  See, e.g., United States v.             
          Janis, 428 U.S. 433, 437 (1976) (upholding projection of 77 days’           
          income based upon 5 days’ gross proceeds as indicated in wagering           
          records); United States v. Besase, 623 F.2d 463, 468 (6th Cir. 1980)        
          (upholding reconstruction of income based on 4 days’ gross gambling         
          receipts as indicated on adding machine tapes).  Obviously, the             
          reliability of the results obtained under this method depends upon          
          the reliability of the starting point; i.e., the adequacy of the            
          data used to extrapolate the projected income.  Cf. Thomas v.               
          Commissioner, 223 F.2d 83, 89 (6th Cir. 1955) (“‘To be dependable,          
          however, the [net worth] method requires a starting point,                  
          reasonably well established as accurate.’” (quoting Gariepy v.              
          United States, 189 F.2d 459, 461 (6th Cir. 1951))).                         
               In employing the projection method here, respondent used as his        
          starting point petitioner’s alleged illegal receipts for the month          
          of August 1988.  To arrive at this starting point, respondent relied        
          upon information derived from a notebook that the Akron Police              
          Department allegedly seized from petitioner’s briefcase upon his            
          arrest at 80 S. Portage Path, in Akron, Ohio.                               
               At trial, respondent sought to introduce into evidence certain         
          photocopied pages (the photocopied pages) that respondent claimed to        
          be a true copy of the notebook in question.  Respondent was unable          








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