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sufficient to establish the amount of gross income, deductions,
credits, or other matters required to be shown by such person in
any return of such tax”.
Petitioner did not maintain any books of account for his
medical practice or his other activities. Petitioner’s counsel
acknowledged that petitioner’s records consisted of “just gross
receipts, a massive amount of receipts, he does not keep journals
and stuff like that”. Petitioner did not offer any books of
account into evidence.
Before filing the petition in this case, petitioner refused
to produce any documents in response to respondent’s informal and
formal requests or to substantiate the income and deductions
reported on his and his trusts’ Federal income tax returns.
Petitioner improperly refused to provide any documents related to
his trusts. Petitioner refused to produce his personal return
documents unless respondent provided acceptable (to him) written
responses to his questions. Petitioner’s questions were
improper, and he had no right to require responses to them before
producing documents. Even though respondent was under no
obligation to do so, respondent provided clear written responses
to petitioner’s improper questions. Even after receiving the
responses, petitioner failed to produce any documents to support
his returns. Petitioner provided no support for his contention
that he was under some privilege not to produce the trust
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