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also Estate of Mason v. Commissioner, 64 T.C. 651, 656 (1975),
affd. 566 F.2d 2 (6th Cir. 1977). When a taxpayer fails to keep
adequate books and records, the Commissioner is authorized to
determine the existence and amount of the taxpayer’s income by
any method that clearly reflects income. Sec. 446(b); Mallette
Bros. Const. Co. v. United States, 695 F.2d 145, 148 (5th Cir.
1983); Webb v. Commissioner, 394 F.2d 366, 371-372 (5th Cir.
1968), affg. T.C. Memo. 1966-81; see also Holland v. United
States, 348 U.S. 121, 131-132 (1954). The Commissioner’s
reconstruction of a taxpayer’s income need only be reasonable in
light of all surrounding facts and circumstances. Schroeder v.
Commissioner, 40 T.C. 30, 33 (1963); see also Giddio v.
Commissioner, 54 T.C. 1530, 1533 (1970). The Commissioner is
given latitude in determining which method of reconstruction to
apply when taxpayers fail to maintain adequate books and records.
Boyett v. Commissioner, 204 F.2d 205, 208 (5th Cir. 1953), affg.
a Memorandum Opinion of this Court dated Mar. 14, 1951; Kenney v.
Commissioner, 111 F.2d 374, 375 (5th Cir. 1940), affg. a
Memorandum Opinion of this Court dated July 28, 1938; Petzoldt v.
Commissioner, 92 T.C. 661, 693 (1989). The method of
reconstruction employed by the Commissioner is not invalidated
solely because the Commissioner’s income determination may not be
completely correct. DiLeo v. Commissioner, supra at 868; see
also Marcello v. Commissioner, 380 F.2d 494, 497 (5th Cir. 1967),
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