- 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).
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