George Maciel - Page 22

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          maintain books and records sufficient to establish the amount of            
          his gross income.  Sec. 6001; DiLeo v. Commissioner, supra at               
          867.  The Secretary is authorized to reconstruct income in                  
          accordance with any reasonable method that accurately reflects              
          actual income.  Secs. 446(b), 6001; Petzoldt v. Commissioner, 92            
          T.C. 661, 687 (1989); Meneguzzo v. Commissioner, 43 T.C. 824, 831           
          (1965).  The reconstruction of a taxpayer’s income need only be             
          reasonable in light of all surrounding facts and circumstances.             
          Giddio v. Commissioner, 54 T.C. 1530, 1533 (1970); Schroeder v.             
          Commissioner, 40 T.C. 30, 33 (1963).                                        
               To reconstruct petitioner’s gross income, respondent                   
          utilized both the specific items and bank deposits methods.  The            
          specific items and bank deposits methods of income reconstruction           
          have long been sanctioned by the courts.  Clayton v.                        
          Commissioner, 102 T.C. 632, 645 (1994); Estate of Mason v.                  
          Commissioner, 64 T.C. 651, 656 (1975), affd. 566 F.2d 2 (6th Cir.           
          1977).  “If the taxpayer feels that the Government’s method of              
          computation is unfair or inaccurate, the burden is on him to show           
          such unfairness or inaccuracy.”  DiLeo v. Commissioner, supra at            
          871.                                                                        
                    (a)  Specific Items of Unreported Income From                     
          Petitioner’s Sale of Tri-City Truck Parts                                   
          and Newark Wreckers                                                         
               Petitioner held his interests in Tri-City and Newark                   
          Wreckers under the name M&V Investments.  As found above,                   






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