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We turn now to respondent's reconstruction of petitioner's
income by use of BLS statistics. Where a taxpayer has not filed
a tax return, respondent may reconstruct the taxpayer's
unreported income. Holland v. United States, 348 U.S. 121
(1954). 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).
Petitioner invoked the jurisdiction of this Court but at
trial did not produce evidence to rebut the fact that he had
sources of income during 1993 and 1994. Petitioner possessed
records that he believed would show that he was not obligated for
tax, but he declined and refused to show those records. A
blanket invocation of the Fifth Amendment privilege is simply not
a substitute for relevant evidence. United States v. Rylander,
460 U.S. 752 (1983); Petzoldt v. Commissioner, 92 T.C. 661, 687-
688 (1989). This Court has observed that
A valid assertion of the privilege against self-
incrimination, however, is not a "substitute for
evidence that would assist in meeting a burden of
production," for to adopt such a view "would convert
the privilege from the shield against compulsory self-
incrimination which it was intended to be into a sword
whereby a claimant asserting the privilege would be
freed from adducing proof in support of a burden which
would otherwise have been his." * * * [Petzoldt v.
Commissioner, supra at 684-685 (quoting United States
v. Rylander, supra at 758).]
The uncontroverted evidence produced by respondent and
petitioner's testimony shows that petitioner did earn income
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