- 9 - 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,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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