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(1933). The taxpayer’s burden includes the burden of
substantiation. Hradesky v. Commissioner, 65 T.C. 87, 90 (1975),
affd. per curiam 540 F.2d 821 (5th Cir. 1976). A taxpayer is
required to maintain sufficient records to substantiate
deductions claimed on the tax return. Sec. 6001.
Petitioner has not attempted to substantiate the portion of
the home mortgage interest deduction claimed on his 1987 return
that was disallowed by respondent. We accordingly sustain
respondent’s determination with respect to the allowable amount
of the deduction.
Unreported Income
Respondent used indirect methods of reconstructing
petitioner’s income for the years in issue. Deficiencies
determined by indirect methods of proof are presumed correct, and
the burden is on the taxpayer to show any claimed unfairness or
inaccuracy in the Commissioner’s calculations. Webb v.
Commissioner, 394 F.2d 366, 372 (5th Cir. 1968), affg. T.C. Memo.
1966-81; Marcello v. Commissioner, 380 F.2d 494, 497 (5th Cir.
1967), affg. in part and revg. and remanding in part T.C. Memo.
1964-302; DiLeo v. Commissioner, 96 T.C. 858, 871, (1991), affd.
959 F.2d 16 (2d Cir. 1992); Harper v. Commissioner, 54 T.C. 1121,
1129 (1970). The reconstruction of income need only be
reasonable in light of all surrounding facts and circumstances.
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