Nick and Helen Kikalos - Page 13

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               taxable income for each taxable year and must maintain                 
               such accounting records as will enable him to file a                   
               correct return.  See section 6001 and the regulations                  
               thereunder.  Accounting records include the taxpayer's                 
               regular books of account and such other records and                    
               data as may be necessary to support the entries on his                 
               books of account and on his return * * *"                              
               Respondent's determination of taxable income is                        
          presumptively correct.  Rule 142(a); Welch v. Helvering, 290 U.S.           
          111, 115 (1933); Mendelson v. Commissioner, 305 F.2d 519, 522               
          (7th Cir. 1962), affg. T.C. Memo. 1961-319.                                 
               Where a taxpayer fails to maintain or produce adequate books           
          and records, the Commissioner is authorized to compute the                  
          taxpayer's taxable income by any method which, in the                       
          Commissioner's opinion, clearly reflects the taxpayer's income.             
          Sec. 446(b); Holland v. United States, 348 U.S. 121, 134 (1954);            
          Webb v. Commissioner, 394 F.2d 366, 371-372 (5th Cir. 1968),                
          affg. T.C. Memo. 1966-81; Harbin v. Commissioner, 40 T.C. 373,              
          377 (1963).  The Commissioner's method need not be exact but must           
          only be reasonable in light of the surrounding facts and                    
          circumstances.  Holland v. United States, supra; Rowell v.                  
          Commissioner, 884 F.2d 1085, 1087 (8th Cir. 1989), affg. T.C.               
          Memo. 1988-410; Giddio v. Commissioner, 54 T.C. 1530, 1533                  
          (1970).                                                                     
               Here, the principal issue is the amount of petitioners'                
          gross income for the years in issue.  Petitioners' bookkeeping              
          practices have failed to produce "such other records and data as            
          may be necessary to support the entries on his books of account             




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