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had the help of an accountant, and he still had not organized his
records. This is inexcusable. Petitioner’s posttrial motion to
be relieved of the stipulation of facts and the other documents
referred to above are simply a continuation of this conduct.
Petitioner’s motion will be denied.
2. The Deductions
For reasons that are apparent, we combine our findings of
facts with our discussion. Petitioner was a residential building
contractor during 1998. The parties agree that petitioner had
gross receipts of $107,668. While he did have a checking
account, petitioner received from his customers and paid to his
suppliers mostly cash. Petitioner kept no books of record of his
income or expenses. Rather he seems to have used a record-
keeping method of throwing receipts in a box and thereafter
ignoring the box when the return was prepared. On Schedule C
petitioner claimed total expenses of $100,330 or approximately 93
percent of his gross receipts. Even though he prepared the 1998
return, petitioner cannot explain the entries on the return.
Upon examination, respondent disallowed $36,914 of the expenses
claimed. Under respondent’s view, petitioner’s expenses were
approximately 59 percent of his gross receipts.
At trial petitioner’s testimony was often vague and
contradictory. Many of the receipts that petitioner presented
are made out to his brother, who was also a contractor, and/or
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