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taxable period from records of income produced by the activity in
question over some shorter period. See, e.g., United States v.
Janis, 428 U.S. 433, 437 (1976) (upholding projection of 77 days’
income based upon 5 days’ gross proceeds as indicated in wagering
records); United States v. Besase, 623 F.2d 463, 468 (6th Cir. 1980)
(upholding reconstruction of income based on 4 days’ gross gambling
receipts as indicated on adding machine tapes). Obviously, the
reliability of the results obtained under this method depends upon
the reliability of the starting point; i.e., the adequacy of the
data used to extrapolate the projected income. Cf. Thomas v.
Commissioner, 223 F.2d 83, 89 (6th Cir. 1955) (“‘To be dependable,
however, the [net worth] method requires a starting point,
reasonably well established as accurate.’” (quoting Gariepy v.
United States, 189 F.2d 459, 461 (6th Cir. 1951))).
In employing the projection method here, respondent used as his
starting point petitioner’s alleged illegal receipts for the month
of August 1988. To arrive at this starting point, respondent relied
upon information derived from a notebook that the Akron Police
Department allegedly seized from petitioner’s briefcase upon his
arrest at 80 S. Portage Path, in Akron, Ohio.
At trial, respondent sought to introduce into evidence certain
photocopied pages (the photocopied pages) that respondent claimed to
be a true copy of the notebook in question. Respondent was unable
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