- 10 - 1988 Gain from sale of stock and commodities $ 27,226 Interest 71 Compensation 15,000 Checks 114,080 Judgments against petitioner (88,222) Bank deposits Guardian State Bank 34,532 Utah Central Credit Union 102,199 Utah Central Credit Union 116,058 $ 320,944 1989 Gain from sale of stock and commodities $ 83,165 Compensation 59,155 Judgments against petitioner (10,851) Bank Deposits Utah Central Credit Union 34,925 Utah Central Credit Union 79,010 $ 245,404 OPINION Where a taxpayer fails to maintain adequate books and records, respondent is entitled to reconstruct a taxpayer's income by any reasonable method. Sec. 446(b); Erickson v. Commissioner, 937 F.2d 1548, 1553 (10th Cir. 1991), affg. T.C. Memo. 1989-552; Parks v. Commissioner, 94 T.C. 654, 658 (1990); United Dressed Beef Co. v. Commissioner, 23 T.C. 879, 885 (1955). Section 61 provides that gross income includes all income from whatever source derived. Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 431 (1955). Income "constitutes taxable income when * * * [a taxpayer] has such control over it that, as a practical matter, * * * [the taxpayer] derives readily realizable economic value from it." Rutkin v. United States, 343 U.S. 130, 137 (1952).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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