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The reconstruction need only be reasonable in light of all facts
and circumstances. Giddio v. Commissioner, 54 T.C. 1530 (1970).
Petitioners have not persuaded us that the gross receipts so
determined should be reduced. We do not believe petitioners’
unsupported claim that only 45 percent of the fees charged were
received. We have no reliable basis for any estimate of the
amounts not paid.
To reflect concessions by respondent,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011