Alan Michael Newman - Page 5

                                        - 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,                     
               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             

Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011