Larry L. Bennett - Page 5

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          $48,847, $51,436, $53,732, $56,169, $58,697 for the taxable years           
          1987 to 1993, respectively.                                                 
          Discussion                                                                  
               Section 61 provides that gross incomes includes income                 
          derived from a business and as compensation for services.  This             
          income is subject to the tax imposed by section 1.  Section 63(b)           
          provides that, in the case of an individual who does not elect to           
          itemize deductions, the term "taxable income" means gross income            
          minus the standard deduction and the deduction for personal                 
          exemptions.  Respondent allowed petitioner these deductions.                
               Taxpayers are required to maintain books and records                   
          sufficient to establish the amount of their gross income.  Sec.             
          6001.  If the taxpayer fails to do this, then respondent is                 
          entitled to reconstruct the taxpayer's income through the use of            
          any reasonable method.  Holland v. United States, 348 U.S. 121              
          (1954).  The reliance on BLS statistics in reconstructing a                 
          taxpayer's income has been held to be reasonable.  See Giddio v.            
          Commissioner, 54 T.C. 1530, 1533 (1970).                                    
               In this case, petitioner neither filed Federal income tax              
          returns nor provided respondent with any books and records                  
          concerning his business income or compensation income.  Respon-             
          dent has linked petitioner to income from his farm rental                   
          activities and his consulting services.  In these circumstances,            
          respondent has broad latitude to reconstruct petitioner's income            





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