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records, which is in itself a basis for imposing the penalty. A
taxpayer is required to maintain records sufficient to establish
information provided on a tax return. Sec. 1.6001-1(a), Income
Tax Regs. Therefore, failure to keep adequate records is
evidence not only of negligence, but of intentional disregard of
the regulations. Marcello v. Commissioner, supra, Magnon v.
Commissioner, 73 T.C. 980 (1980). Here, the taxpayer failed to
maintain records sufficient to establish the amount of gambling
winnings and losses on both his 1990 and 1991 Federal income tax
returns. Accordingly, we hold for respondent.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011