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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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