- 5 - the same local jeweler but kept no receipts to document the transactions. During the years at issue, petitioner kept a calendar that contained notations of his mileage, location, dates worked at the gold mining activity, and some expenditures. He wrote “San Andreas”, “cement plant”, or other notations on days he was dredging or tending to his equipment. These calendars indicate that petitioner worked approximately 39 days during 1994 and 37 days during 1995 either dredging for gold or working at home on his gold dredging equipment. No calendar for 1996 was introduced into evidence, nor was any testimony offered as to how much time petitioner spent on his activity that year. With respect to expenses incurred in the gold mining activity, petitioner did not keep a general ledger or other formal records. He kept some store receipts and canceled checks for items purchased for the mining operation and had photographs of his dredging and gold mining equipment. Other expenses and items, such as mileage, were documented only by notations on petitioner’s calendar or using receipts handwritten by petitioner or acquaintances who had sold petitioner pieces of equipment. At least some of these homemade receipts were not prepared contemporaneously with the transactions. Rather, petitioner admitted that he took inventory and gathered his receipts in 1997Page: 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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