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he earned between $30,000 and $40,000 from his truck driving
activities in 1991, the year immediately following the 2 years in
issue. This evidence from 1991 indicates that petitioner was
capable of earning from truck driving the amounts determined by
respondent to be unreported gross receipts in the years in issue.
The Court of Appeals for the Seventh Circuit has made clear
in this context that, in order for a deficiency determination to
be entitled to the presumption of correctness, it need not
pinpoint the exact amount of the deficiency. Rather, the
determination need only be rationally based.
It is significant that we have described the necessary
showing as "arbitrary and erroneous," not just
"erroneous." As the Eighth Circuit has observed in a
related context, the Commissioner's "assessment is
intended to be an estimate. It is expected to be
rational not flawless." [Pittman v. Commissioner, 100
F.3d 1308, 1317 (7th Cir. 1996), affg. T.C. Memo. 1995-
243; citations omitted.]
Because there is sufficient predicate evidence to support the
deficiency determination, we conclude that the unreported
Schedule C gross receipts determinations made by respondent are
not arbitrary and erroneous or without rational foundation.
Section 6001 requires a taxpayer to maintain adequate
records supporting the amount of gross income, deductions,
credits, and other matters required to be shown on his income tax
return. See sec. 1.6001-1(a), Income Tax Regs. We find that
petitioner failed to keep adequate records relating to his cash
receipts from Lighthouse as required by section 6001. Petitioner
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