Richard T. Wallace - Page 4

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          Respondent then took the adjusted expenditures for one person and           
          applied the Consumer Price Index based on the Denver area to                
          determine the necessary income for petitioner to live on during             
          1990 through 1993.  Thus, the Bureau of Labor Statistics method             
          resulted in determined income of $22,034 for 1990, $22,886 for              
          1991, $23,733 for 1992, and $24,738 for 1993.                               
               Section 61 provides, in part, that gross income means income           
          derived from business and as compensation for services.  Section            
          63(b) provides that, in the case of an individual who does not              
          elect to itemize deductions, the term "taxable income" means                
          adjusted gross income minus the standard deduction and the                  
          deduction for personal exemptions.  Section 63(c) provides the              
          amount of the basic standard deduction for the years 1990 through           
          1993 for an individual married and filing separately.  Respondent           
          allowed petitioner these deductions.                                        
               Section 151 provides for a personal exemption.  Petitioner             
          presented no evidence that he is entitled to claim any exemption            
          other than for himself.                                                     
               Petitioner was required to maintain books and records                  
          sufficient to establish the amount of his gross income.  Sec.               
          6001; DiLeo v. Commissioner, 96 T.C. 858, 867 (1991), affd. 959             
          F.2d 16 (2d Cir. 1992).  He failed to do so.  Therefore,                    
          respondent was authorized to compute petitioner's income by any             
          method that clearly reflected income.  Sec. 446(b); Holland v.              
          United States, 348 U.S. 121 (1954).  Any such reconstruction of             




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