- 35 - cited therein; see also Erickson v. Commissioner, 937 F.2d 1548, 1552-1553 (10th Cir. 1991), affg. T.C. Memo. 1989-552. A. Schedule C Income--1982 Petitioner contends that he reported all income that was known to him, and that any difference between expenses and revenue came from loans or from disinvestment, e.g., sales of assets. Petitioner also claims that on December 31, 1981, he had a net worth of more than $1 million, and points out that by 1987 he was bankrupt. Respondent contends that petitioner received and omitted Schedule C income for 1982 in the amount of $185,512. See supra table 4, for a comparison of respondent's determinations in the notice of deficiency and respondent's position on brief. We agree in part with respondent and in part with petitioner. (1) Background When petitioner filled out his tax returns for the years in issue (supra table 2), he did so by using his memory, estimating figures, and looking at old check registers and assorted receipts. Petitioner did not keep his records in an organized manner. About 4 months after petitioner filed his 1982 tax return, and just after he filed his 1986 tax return, in January 1988, some of petitioner's records were inadvertently shipped away. In June 1989, petitioner brought three boxes of unsorted records to Burns' office, but was told to take them back and sortPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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