- 11 - method for computing * * * [the taxpayer's] true income." Schroeder v. Commissioner, T.C. Memo. 1989-110 (held that the use of income figures listed on invalid Federal income tax returns was a reasonable method of reconstructing the taxpayer's income); see also Hill v. Commissioner, T.C. Memo. 1995-136, affd. without published opinion 86 F.3d 1155 (6th Cir. 1996); Schroeder v. Commissioner, T.C. Memo. 1986-583. Therefore, respondent's use of this method of reconstruction was well within the discretion of respondent. Sec. 446(b). At trial, respondent also introduced summaries of numerous checks drawn on FCE's account, which list Ms. Fischer as the payee. Ms. Fischer identified the checks which were cashed for petitioner. These checks totaled $33,746.01 in 1988, $34,018.99 in 1989, and $6,759.86 in 1990. These amounts exceed the income reported by petitioner on his delinquent returns for these respective years. We found Ms. Fischer's testimony persuasive and, consequently, find that petitioner received income during 1988, 1989, and 1990 in amounts greater than that reported on his Federal income tax returns for these years. Respondent also presented evidence that petitioner received unreported income, including checks written on PCG's corporate account during 1990 and 1991, which list petitioner as the payee. These checks totaled $39,219.91 in 1990 and $82,162.80 in 1991.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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