Nick Kikalos and Helen Kikalos - Page 8

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          in the amount of $165, was dated January 13, 1997.  Respondent              
          determined that petitioner failed to include those checks                   
          totaling $1,059 in gross receipts.  Petitioner did not provide              
          respondent records to substantiate that these payments were                 
          properly included in income.                                                
               Before their 1997 tax year, petitioners were notified on               
          several occasions that their records were inadequate.  In the               
          case of Kikalos v. Commissioner, T.C. Memo. 1998-92, revd. in               
          part 190 F.3d 791 (7th Cir. 1999), this Court found that                    
          petitioner’s records with respect to Nick’s Liquors were                    
          inadequate for 1990, 1991, and 1992.  In that opinion it was                
          noted that petitioner had been advised to retain adequate records           
          before his 1990 and 1991 tax years.  Further, on June 9, 1995,              
          petitioner entered into a records retention agreement with the              
          Internal Revenue Service agreeing that he would maintain certain            
          records.  Petitioner did not adequately comply with his June 9,             
          1995, agreement.                                                            
                                       OPINION                                        
               We consider here whether petitioner has shown that                     
          respondent’s determination is in error.  Respondent determined              
          that petitioner failed to report business income from several               
          sources.  In spite of numerous warnings, petitioner did not                 
          maintain adequate records for 1997.  Petitioner knowingly                   








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