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Petitioner claims that for the 1991 tax year, he provided
respondent a complete set of original dog racing programs to
substantiate the income reported on his Federal income tax return
but that some of the programs were lost by respondent.6 However,
at trial, both of respondent's tax auditors who were working on
petitioner's audit, testified that they never received the pro-
grams for the second half of 1991. Petitioner failed to present
any evidence to support his claim that he delivered these pro-
grams to respondent. He presented no receipt for the programs
and offered no testimony or other evidence to corroborate his
story. Thus, petitioner presented an incomplete picture of his
1991 gambling activities.
When a taxpayer fails to maintain adequate books and
records, the Commissioner is authorized to reconstruct income by
any reasonable means which will clearly reflect income. Holland
v. United States, 348 U.S. 121, 130-132 (1954); Conforte v. Com-
missioner, 74 T.C. 1160, 1181 (1980), affd. in part and revd. in
part 692 F.2d 587 (9th Cir. 1982). Extrapolation is a permissi-
ble method of proving the volume of unreported wagers. Gordon v.
Commissioner, 572 F.2d 193, 195 (9th Cir. 1977); Carson v. United
States, 560 F.2d 693 (5th Cir. 1977).
6Petitioner also provided respondent with a ledger showing
petitioner's net winnings or losses for each day that he gambled,
and the cumulative running total of petitioner's net winnings or
losses for the year. However, petitioner admitted both at the
audit and at trial that the ledger was inaccurate.
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