- 5 - rejected by this and other courts. See, e.g., Wilcox v. Commissioner, 848 F.2d 1007 (9th Cir. 1988), affg. T.C. Memo. 1987-225. We shall not painstakingly address petitioner's assertions "with somber reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit." Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984). Suffice to say, petitioner is subject to Federal income tax during the relevant years, and we sustain respondent's determination. Issue 2. Additional Unreported Income Utilizing Bureau of Labor Statistics' data, respondent determined that, in addition to the above referenced wages and nonemployee compensation, petitioner had unreported income of $21,178, $19,771, and $10,913 for 1990, 1991, and 1993, respectively. Every taxpayer is required to maintain adequate records of taxable income. Sec. 6001. Petitioner did not maintain adequate records from which the amount of his income or Federal income tax liability could be computed. In the absence of such records, a taxpayer's income may be reconstructed by any method that, in the Commissioner's opinion, clearly reflects income. Sec. 446(b); Parks v. Commissioner, 94 T.C. 654, 658 (1990). The Commissioner's method need not be exact but must be reasonable. Holland v. United States, 348 U.S. 121 (1954). The reliance onPage: Previous 1 2 3 4 5 6 7 Next
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