- 6 - Year Amount 1993 $517,236 1994 477,903 1995 333,780 Respondent allowed petitioners’ business deductions for the roofing business that were claimed on petitioners’ joint Federal income tax returns. Respondent also determined, for each year, that petitioners were liable for the fraud penalty under section 6663. In the alternative, for each year, respondent determined that petitioners were liable for the accuracy-related penalty under section 6662. As a protective measure, on audit of Delwin Houser for 1993, 1994, and 1995, respondent charged to Delwin Houser the same total amounts of unreported income relating to the bank deposits that were charged to petitioners. OPINION Under section 61, gross income includes all income from whatever source derived. See Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 431 (1955). Taxpayers are required to maintain sufficient records to allow respondent to determine their correct Federal income tax liability. See sec. 6001. Generally, respondent’s determinations are presumed correct, and taxpayers have the burden of proving that respondent’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011