- 8 - Moreover, the check summary covers the entire taxable year and supports respondent’s contention that petitioners had income that was not reported on their return. Petitioners have not contested the accuracy of the check summary. Section 6001 provides generally that every person liable for any tax shall keep such records, render such statements, make such returns, and otherwise comply with applicable rules and regulations for the reporting of income and expenses. To be sure, some of the monthly statements petitioners received from ARL contained inaccuracies; however, petitioners knew that. Petitioners failed to maintain their own books and records to persuade the Court that the information return filed at yearend with respondent by ARL was inaccurate. On this record, the Court finds that petitioners did receive $51,470 in unreported income during the year 2000. Respondent is sustained on this issue. Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered under Rule 155.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011