- 22 - 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,Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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