- 11 - that clearly reflects income. Sec. 446(b); Meneguzzo v. Commissioner, 43 T.C. 824, 831 (1965). Because petitioner failed to produce any records, respondent used the CPI Rollover Method to reconstruct petitioner's income for the years in issue. Under this method, income is computed by multiplying the adjusted gross income reported on the taxpayer's most recently filed return by the increase in the CPI, as published by the U.S. Department of Labor, for the year in issue. See Moore v. Commissioner, 722 F.2d 193, 196 (5th Cir. 1984), affg. T.C. Memo. 1983-20. Based on her CPI calculations, respondent determined that petitioner had unreported self-employment income of $28,631, $29,470, $30,851, $32,256, and $33,021 for 1988, 1989, 1990, 1991, and 1992, respectively. Respondent has established that petitioner engaged in a tax consulting practice during 1988 and 1989. During these years, Ms. Boals paid petitioner $150 per hour for his services. Petitioner rented office space from Hercules & Lavery and referred approximately a dozen of his clients to the firm during this same period. In 1988, Virginia Shaw paid petitioner a $5,000 retainer to prepare her 1987 Federal income tax return. In addition, petitioner requested an extension of time to file Ms. Shaw's return, because he was behind on audits and Tax Court cases. Moreover, petitioner testified that he was a tax consultant during 1988 and 1989, and he knew that he had to file returns for these years. Therefore, we conclude that respondentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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