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and (3) $1,867 from the Maultsby Clinic. He has failed to
establish that these funds are excludable from his gross income.
Accordingly, we hold that these funds are includable in his gross
income. See secs. 61(a), 72, 408(d)(1).
The remainder of respondent's determinations relating to Mr.
Cujas for 1992 were supported by evidence. Respondent obtained
Forms 1099 indicating that Mr. Cujas received: (1) $13,214 from
St. John Neuromuscular Therapy Seminars; (2) $630 from Matol
Botanical International Ltd.; (3) $677 from Hartford Life
Insurance Co.; and (4) $493 from the State Employees Credit
Union. Therefore, we conclude that respondent obtained
sufficient evidence to link Mr. Cujas to these funds. As a
result, Mr. Cujas bears the burden of proving that respondent's
determinations relating to these funds are erroneous. He has
failed to provide any credible evidence to carry his burden of
proof. Accordingly, we hold that these funds are includable in
his gross income. See sec. 61(a).
B. 1993 Tax Year
Respondent determined, using BLS data, that during 1993 each
petitioner had gross income of $21,339. Every taxpayer is
required to maintain adequate records of taxable income. Sec.
6001. If the taxpayer fails to maintain such records, the
Commissioner may reconstruct income in accordance with a method
that clearly reflects income. Sec. 446(b); Meneguzzo v.
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