- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011