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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.
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Last modified: May 25, 2011