- 4 -
courts have approved the use of those statistics as an acceptable
and reasonable method of reconstructing income. E.g., Pollard v.
Commissioner, 786 F.2d 1063, 1066 (11th Cir. 1986), affg. T.C.
Memo. 1984-536; Giddio v. Commissioner, 54 T.C. 1530, 1532-1533
(1970).
Petitioner admitted at trial that he worked and earned
income during the years at issue, but he claimed that he earned
no more than $500 during each of those years. However, peti-
tioner acknowledged at trial that during the years at issue he
and his family lived at a residence for which the rent paid
equaled at least $725 a month. He also admitted that utilities
were paid at that residence. In addition, petitioner acknowl-
edged at trial that during the years at issue he owned an automo-
bile and that other normal living expenses were paid for him and
his family.
We found petitioner's testimony, which was at times vague
and evasive, to be suspect. We question petitioner's testimony
that he earned no more than $500 during each of the years at
issue.2
2 Indeed, petitioner's testimony that he earned no more than
$500 during each of the years at issue is inconsistent with other
evidence in the record. For example, the application to rent
dated Mar. 13, 1989, which he signed, indicated "current monthly
income" of $3,000. Even assuming arguendo that the "current
monthly income" of $3,000 that petitioner listed in the
application to rent dated Mar. 13, 1989, were the combined
"current monthly income" of Ms. Diercks and himself, the Internal
Revenue Service's information returns master file transcript for
(continued...)
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