- 8 - 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 knowinglyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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