- 27 - 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, petitionerPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011