Gregory Alberico - Page 12

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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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