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Bureau of Labor Statistics' data in reconstructing a taxpayer's
income has been held to be reasonable. Giddio v. Commissioner,
54 T.C. 1530 (1970); Bennett v. Commissioner, T.C. Memo. 1998-96.
Respondent attempted to obtain information from petitioner
once he had been identified as a nonfiler. Petitioner was not
cooperative. Respondent obtained information from the various
institutions that reported Form 1099 information regarding
petitioner. Respondent reconstructed petitioner's income using
this Form 1099 data. Respondent also increased petitioner's
income using amounts determined from the Bureau of Labor
Statistics. In doing so, respondent increased petitioner's 1990,
1991, and 1993 taxable income by $21,178, $19,771, and $10,913,
respectively.
Petitioner testified that he was single and that his living
expenses were minimal. Petitioner spent some part of the years
in issue living rent free with a friend. When petitioner did pay
rent during the years in issue, it varied from $250 to $350 per
month, which included utilities.2 Petitioner did not eat out
very often. Petitioner's phone bill was approximately $25 per
month. Petitioner did not have any medical expenses during the
years in issue and did not have medical insurance. Petitioner
2 Petitioner also testified that this amount included
food. From this amount approximately $20 to $30 per week was
spent on groceries.
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Last modified: May 25, 2011