- 8 - amended petition, or otherwise preserved. Petitioners’ untimely attempt herein to raise new issues will be denied. Taxpayers have a duty to maintain accurate and credible books and records that relate to their income and deductions for each year and that are necessary for a proper determination of their Federal income tax liability. Sec. 6001. As has been said, "The United States has relied for the collection of its income tax largely upon the taxpayer's own disclosures * * *. This system can function successfully only if those within and near taxable income keep and render true accounts." Spies v. United States, 317 U.S. 492, 495 (1943). The burden of proof is on petitioners to prove by a preponderance of the evidence their entitlement to the deductions, losses, credits, and other adjustments that are in dispute in this case. Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933). With the exception of a $21,222 trucking expense, discussed below, petitioners have failed to satisfy their burden of proof on each issue, and, with the exception noted, we hold for respondent on each issue. Many of petitioners' arguments in their posttrial briefs are barely comprehensible. Below, we attempt to make some sense out of petitioners’ arguments and to discuss further the sparse and confusing facts in the record relating to each primary issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011