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taxable income but is not required to trace deposits to their
source. Petzoldt v. Commissioner, 92 T.C. 661, 695-696 (1989).
We examine the record to determine whether there is a
minimal evidentiary foundation supporting respondent's
determination of unreported income. We find that there is.
Every individual liable for tax is required to maintain
books and records sufficient to establish the amount of his or
her gross income. Sec. 6001; DiLeo v. Commissioner, 96 T.C. 858,
867 (1991), affd. 959 F.2d 16 (2d Cir. 1992). Where a taxpayer
fails to maintain or produce adequate books and records, the
Commissioner is authorized to compute the taxpayer's taxable
income by any method that clearly reflects income. Sec. 446(b);
Holland v. United States, 348 U.S. 121 (1954); Webb v.
Commissioner, 394 F.2d 366, 371-372 (5th Cir. 1968), affg. T.C.
Memo. 1966-81. The reconstruction of income need only be
reasonable in light of all surrounding facts and circumstances.
Giddio v. Commissioner, 54 T.C. 1530, 1533 (1970). The
Commissioner is given latitude in determining which method of
reconstruction to apply when a taxpayer fails to maintain
records. Petzoldt v. Commissioner, supra at 693.
For the years in question, petitioner maintained inadequate
books and records. Petitioner's bookkeeping consisted of a few
sheets of paper which lacked indicia of reliability. Respondent
employed the specific items method of proof to reconstruct
petitioner's gross receipts from his medical practice. This
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