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that business, the evidence to the contrary provided by her
clientele is overwhelming. That evidence nonetheless falls short
of providing us with a firm basis upon which to calculate her
income from those activities. Perhaps unsurprisingly, few of the
witnesses have been entirely forthcoming, leaving us with an
unsatisfactory record.
Respondent has used the specific item method of
reconstructing petitioner’s income for 1989 and 1990. This
method depends upon proof of specific items of income that were
omitted from the taxpayer’s return. In Estate of Beck v.
Commissioner, 56 T.C. 297, 353 (1971), the Court stated: “the
‘specific item’ method of proof * * * simply consists of evidence
of particular or specific amounts of taxable income received by
the taxpayer during a particular tax period, with evidence that
the taxpayer did not include such amounts in his tax return”.
See also United States v. Merrick, 464 F.2d 1087, 1092 (10th Cir.
1972). In most instances, petitioner has presented evidence
disputing the specific amounts or taxability of the items in
question. We have used our best judgment on the basis of the
record before us to arrive at the amounts of income involved.
Respondent determined that petitioner had unreported escort
income of $3,600 in 1989 and $3,600 in 1990 from an individual
named Dennis T. Dennis T. testified, however, that he had only
legitimate business dealings with petitioner. He conceded that
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