- 19 - organized. Furthermore, the records were not complete. The auditor was unable to find journal tapes and the cash register tapes for the 3 sample months that she initially chose, and was forced to select different months. The report of the sales tax audit states that “the accounting records flow through to the financials without a hitch. However, the bar business is mostly cash and income is easily hidden from normal view.” The auditor found that the deposit slips for the business show that deposits consisted mostly of checks. She found that to be unusual because bars are typically high cash businesses. The auditor noted in the audit report that “The taxpayer did not use due care in reporting all sales and deliberately hid income.” On the basis of the foregoing, we find that respondent was justified in using an indirect method of reconstructing income. The percentage or unit markup method is an acceptable method of reconstructing a taxpayer’s income. See Langworthy v. Commissioner, T.C. Memo. 1998-218; Stewart v. Commissioner, T.C. Memo. 1990-264 (citing Tunningley v. Commissioner, 22 T.C. 1108 (1954); Stone v. Commissioner, 22 T.C. 893 (1954)).Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011