Reliable Credit Association, Inc. - Page 9

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          Harbin v. Commissioner, supra at 377.  Further, the Commissioner            
          is not required to make estimations or ferret out every possible            
          itemized deduction.  Conforte v. Commissioner  74 T.C. 1160,                
          1177-1178 (1980), affd. in part and revd. and remanded in part on           
          other grounds 692 F.2d 587 (9th Cir. 1982).                                 
               Petitioner does not directly attack the method of accounting           
          that respondent used in determining its income and deductions,              
          and we have not been informed as to that methodology.  Rather,              
          petitioner asserts that a taxpayer is not required to                       
          substantiate its gross income provided taxable income can be                
          determined with reasonable accuracy.  Given the definition of               
          taxable income and the recordkeeping requirements, we disagree,             
          and conclude that petitioner was required to keep records                   
          sufficient to establish the amount of its gross income.  DiLeo v.           
          Commissioner, 96 T.C. 858, 867 (1991), affd. 959 F.2d 16 (2d Cir.           
          1992).  Accordingly, we find petitioner's argument that                     
          respondent's position was not substantially justified is fatally            
          flawed.  See Amann v. Commissioner, T.C. Memo. 1993-542, affd.              
          without published opinion 40 F.3d 1235 (1st Cir. 1994);                     
          Chiaffarano v. Commissioner, T.C. Memo. 1992-614.                           
               Petitioner makes other arguments, most of which rely to some           
          extent on the premise that petitioner was not required to keep              
          records sufficient to establish the amount of its gross income,             







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