- 15 - $46,277, and $42,443, respectively. During the same years, petitioner reported Schedule F losses from the horse breeding activity of $9,136, $23,533, and $12,697, respectively. Petitioner used these losses to reduce her gross income by approximately 21 percent for 1996, 51 percent for 1997, and 30 percent for 1998. These reductions led to substantial tax savings for petitioner. Considering all the facts and circumstances, we find that petitioner’s horse breeding activity was not engaged in for profit within the meaning of section 183(c). Respondent’s determination is therefore sustained. C. Petitioner’s Unreported Income As previously noted, taxpayers are required to maintain records sufficient to show whether they are liable for Federal income taxes. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs. If a taxpayer fails to keep adequate records, the Commissioner may reconstruct the taxpayer’s income by any method that is reasonable under the circumstances. See Petzoldt v. Commissioner, 92 T.C. 661, 687 (1989). The bank deposits and cash expenditures method is recognized as a reasonable method of reconstructing income. See Parks v. Commissioner, 94 T.C. 654, 658 (1990); Nicholas v. Commissioner, 70 T.C. 1057, 1065 (1978). This method is premised on the assumption that the taxpayer has disposed of unreported income byPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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