- 10 - respondent used an understated amount of cash on hand in the calculation of petitioners’ business income. A larger amount of cash on hand would reduce respondent’s income determination under the source and application of funds method. Taxpayers are required to keep adequate records with which the Commissioner may determine their correct tax liability. See sec. 6001; sec. 1.6001-1(a), (d), Income Tax Regs. In the absence of such adequate records, the Commissioner may reconstruct income using a method that clearly reflects income. See Cebollero v. Commissioner, 967 F.2d 986, 989 (4th Cir. 1992), affg. T.C. Memo. 1990-618; Petzoldt v. Commissioner, 92 T.C. 661, 687 (1989). The Commissioner may use indirect methods to reconstruct income, so long as they are reasonable in the circumstances. See Holland v. United States, 348 U.S. 121, 126 (1954); Giddio v. Commissioner, 54 T.C. 1530, 1532-1533 (1970). Respondent reconstructed petitioners’ income using the source and application of funds method. Petitioners do not question respondent’s use of the source and application of funds method for reconstructing their income. Petitioners argue, however, that respondent’s determination of their income was overstated because respondent used too small an amount of cash on hand in the computation. Petitioners do not question other aspects of respondent’s calculations. Accordingly, we must consider whether respondent erred in the reconstruction of petitioners’ income only with respect to the amount of cashPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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