Harry Allen and Evelyn Scott Hall - Page 9

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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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