Joseph Alan Piole - Page 27




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          Deficiencies                                                                
               Petitioner failed to maintain adequate books and records as            
          required by section 6001.  Accordingly, respondent relied on the            
          net worth method as a means to indirectly reconstruct                       
          petitioner's income for the years in issue.  See Holland v.                 
          United States, 348 U.S. 121 (1954); Goodmon v. Commissioner, 761            
          F.2d 1522, 1524 (11th Cir. 1985); Cupp v. Commissioner, 65 T.C.             
          68, 82 (1975), affd. without published opinion 559 F.2d 1207 (3d            
          Cir. 1977).  From our examination of respondent's net worth                 
          calculations, we are satisfied that these calculations comport              
          with the requirements of Holland v. United States, supra.  In               
          particular, respondent made adequate opening cash-on-hand                   
          computations, established a likely source of income, and                    
          investigated relevant leads of nontaxable sources of income.  See           
          id. at 130-131.  Respondent's net worth calculations were based             
          on substantial documentary evidence.  Moreover, petitioner has              
          stipulated or is deemed to have admitted many if not all of the             
          adjustments underlying respondent's determinations.  Petitioner             
          bears the burden of proving that respondent's determinations are            
          incorrect.  See Parks v. Commissioner, 94 T.C. 654, 658-659                 
          (1990); Schad v. Commissioner, 87 T.C. 609, 620 (1986), affd.               
          without published opinion 827 F.2d 774 (11th Cir. 1987).                    
          Petitioner failed to offer any credible evidence that                       
          respondent's determinations are erroneous.  At trial, petitioner            






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