Douglas J. Crawford - Page 5

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          and petitioner is subject to the statutory rules, including the             
          Special Trial Judges' authority to hear and decide cases under              
          section 7443A(b)(1), (2), and (3).  See Freytag v. Commissioner,            
          supra at 882.                                                               
          2.  Determination of Deficiency                                             
               Petitioner failed to file an income tax return for 1991.  In           
          determining petitioner's deficiency, respondent reconstructed               
          petitioner's income using information provided by third parties,            
          e.g., Form W-2, Form 1099-INT, and Form 1099-UC.  Petitioner does           
          not dispute the source or amount of income set forth in the                 
          notice of deficiency.  Petitioner has stipulated to receiving the           
          amounts of income set forth in respondent's notice of deficiency.           
          Petitioner's contention is that $570 of the unemployment                    
          compensation he received in 1991 relates to the year 1990 and               
          should not be included in his 1991 gross income.                            
               In reconstructing petitioner's 1991 income, respondent used            
          the cash receipts and disbursement method.  If no method of                 
          accounting has been regularly used by the taxpayer, the                     
          computation of taxable income shall be made under such method as,           
          in the opinion of the Secretary, clearly reflects income.  See              
          sec. 446(b).  Where a taxpayer keeps no established books or any            
          regular system of accounting, his income is to be recomputed on             
          the cash receipts and disbursement method.  See Kotmair v.                  
          Commissioner, 86 T.C. 1253, 1258 (1986).  Under the cash receipts           
          and disbursement method, all items which constitute gross income            

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