- 5 - $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 incomePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011