5
The record includes copies of canceled checks written on a
MAP account in 1992 and 1993 payable to petitioner. The only
items on the checks that were not preprinted are the date,
amount, petitioner's name, and Mark A. Palmer's signature. There
are no references to invoices on the checks. The checks total
$119,492 for 1992 and $106,695 for 1993. The record includes
Forms 1099-Misc issued by MAP to petitioner that show that MAP
paid nonemployee compensation of $119,492.25 to petitioner for
1992 and $106,695.21 for 1993. Petitioner admits that MAP paid
him $119,492 in 1992 and $106,695 in 1993 as compensation for
labor. However, petitioner contends that he kept $49,321.57 of
the money MAP paid him in 1992 and $48,325.40 in 1993 and paid
the rest ($70,170.68 in 1992 and $58,369.81 in 1993) to other
people. Petitioner contends that the money he claims to have
paid to others was not income to him. Petitioner had no canceled
checks, receipts, or other documentary evidence showing that he
paid others. He did not issue any Forms W-2 or Forms 1099. He
did not call any witnesses to testify that he paid them.
Petitioner has not shown that respondent's determination of
income for the years in issue is incorrect. Even if petitioner
paid some workers for their services, his testimony is not a
sufficient basis for deciding how much he paid to them. A
taxpayer must keep adequate records from which to calculate his
or her correct tax liability. Sec. 6001; sec. 1.6001-1(a),
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