- 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 on
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