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While the requirements of sec. 1.6001-1, Income Tax Regs., are
connected with the term "or", in this context, we interpret "or"
in the conjunctive rather than disjunctive. Cf. DeSylva v.
Ballentine, 351 U.S. 570, 573 (1956) (interpreting "or" in the
conjunctive); United States v. One 1973 Rolls Royce, V.I.N. SRH-
16266, 43 F.3d 794, 815 (3d Cir. 1994) (holding that context is
determinative of whether the term "or" is used in the conjunctive
or disjunctive). It is not open to question that taxpayers must
keep records sufficient to establish the amount of income
received, deductions claimed, as well as the amount of any
credit, rather than records that establish just one of the three.
See, e.g., Lias v. Commissioner, 24 T.C. 280, 308 (1955), affd.
235 F.2d 879 (4th Cir. 1956); Rao v. Commissioner, T.C. Memo.
1996-500; Wynn v. Commissioner, T.C. Memo. 1996-415; Baker v.
Commissioner, T.C. Memo. 1994-283; Mitchell v. Commissioner,
T.C. Memo. 1968-137, affd. 416 F.2d 101 (7th Cir. 1969).
In the absence of adequate books and records, the
Commissioner may determine the existence and amount of a
taxpayer's income by any method that clearly reflects income.
Sec. 446(b); Harbin v. Commissioner, 40 T.C. 373, 377 (1963).
The Commissioner may use any reasonable method. DiLando v.
Commissioner, T.C. Memo. 1975-243. No particular method is
required since circumstances will vary in individual cases.
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