-35-
Where * * * there is evidence of taxable income but no
information can be acquired to ascertain the amount of
such income, we do not think it is arbitrary for the
Commissioner to determine that the taxpayer had income
at least equal to the normal cost of supporting his
family. * * *
The parties have made the following stipulations concerning
petitioner's income for 1993 and 1994:
1. Petitioner earned gross income from his plumbing
business in 1993 and 1994.
2. In the course of his plumbing business, petitioner
received payments from White Co. in 1993 and 1994, in amounts
totaling $48,504 and $46,000, respectively.
3. In 1993, petitioner lent $200,000 to White Co., and
received interest income from White Co. in the amount of $20,558.
In addition, petitioner's pleadings admit that petitioner
owed tax for both 1993 and 1994.
The parties have also stipulated as follows concerning
respondent's lack of information about the amount of petitioner's
taxable income for 1993-94:
1. Petitioner did not file a tax return for 1993 or 1994.
2. Respondent has no documentation concerning petitioner's
business expenses for 1993 and 1994.
3. Petitioner did not maintain, as books and records for
1993 or 1994, invoices, receipts for cash disbursements, a
general ledger, a cash receipts journal, or a cash disbursements
journal.
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