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"Arithmetic precision was originally and
exclusively in [the taxpayer's] hands, and he had a
statutory duty to provide it. * * * [H]aving defaulted
in his duty, he cannot frustrate the Commissioner's
reasonable attempts by compelling investigation and
recomputation under every means of income
determination. Nor should he be overly chagrined at
the Tax Court's reluctance to credit every word of his
negative wails."
Petitioner has failed to persuade us that respondent's
determination of his income for any of the years in issue was
erroneous. Petitioner relied heavily on his own testimony to
satisfy his burden of proof. We found most of petitioner's trial
testimony to be general, vague, conclusory, and questionable in
material respects. Under the circumstances presented here, we
are not required to, and generally do not, rely on petitioner's
testimony to sustain his burden of establishing error in
respondent's determinations. See Lerch v. Commissioner, 877 F.2d
624, 631-632 (7th Cir. 1989), affg. T.C. Memo. 1987-295; Geiger
v. Commissioner, 440 F.2d 688, 689-690 (9th Cir. 1971), affg. per
curiam T.C. Memo. 1969-159; Tokarski v. Commissioner, 87 T.C. 74,
77 (1986). We believe that respondent's method of reconstruction
was rational, and accordingly, we sustain respondent's
determination of petitioner's income.
Additions to Tax and Penalties
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