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records that are sufficient to establish the amount of gross
income, deductions, credits, or other amounts on their tax
returns. See sec. 6001; sec. 1.6001-1, Income Tax Regs.
Petitioner failed to keep records so as to show respondent’s
determination is erroneous. Accordingly, we hold that petitioner
failed to report vendor refunds and reimbursement income of
$3,007 for 1997.
V. Insurance Recoveries
Finally, respondent determined that two of the third party
checks totaling $1,059 were attributable to insurance recoveries
not reported as income for 1997. The checks were from insurance
companies, in the amounts of $894 and $165, and dated December
10, 1996, and January 13, 1997, respectively.
With respect to the $894 check, petitioner argues that the
check cannot be attributable to his 1997 income because it must
have been received in 1996. Respondent argues that this check
was one of several checks petitioner used to purchase a cashier’s
check on January 14, 1997. Because petitioner purchased a
cashier’s check on January 7, 1997, and did not use the $894
check, respondent maintains that petitioner must not have
received the check until after January 7, 1997. Therefore, the
check must be attributable to petitioner’s 1997 tax year.
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