John Boyd Tenney - Page 16

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          funds deposited into his money market account at Merrill Lynch              
          and from his bank account at Guardian State Bank.  Petitioner is            
          to be allowed these expenses as deductible business expenses.               
          Petitioner's claim to additional losses and expenses beyond those           
          allowed herein is not supported by the evidence and is denied.              
               We reject petitioner's general claim that over the years in            
          issue he never realized any bottom line net income and that he              
          realized over the years in issue total losses in excess of $20              
          million.  No credible evidence supports the nature and amount of            
          petitioner's claim to total net losses in any of the years before           
          us.                                                                         
               Petitioner points to his bankruptcy filing and to the loss             
          of his residence, and petitioner argues that respondent should              
          have performed a net worth analysis of petitioner's income for              
          the years in issue.  Petitioner alleges that such a net worth               
          analysis would have corroborated losses he claims to have                   
          realized over the years.  Respondent, in this case, is under no             
          obligation to make such a net worth computation.  As indicated,             
          respondent is entitled to reconstruct petitioner's income by any            
          reasonable method.  Erickson v. Commissioner, 937 F.2d at 1553;             
          United Dressed Beef Co. v. Commissioner, 23 T.C. at 885.                    
               With the exceptions noted, we sustain respondent's                     
          determination of petitioner's taxable income for each of the                
          years in issue under the specific item and the bank deposits                
          methods of proof.                                                           




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