- 5 - I. Unreported Schedule C Gross Receipts Section 6001 requires a taxpayer to maintain sufficient records to allow for the determination of the taxpayer’s correct tax liability. Petzoldt v. Commissioner, 92 T.C. 661, 686 (1989). If a taxpayer fails to maintain or does not produce adequate books and records, the Commissioner is authorized to reconstruct the taxpayer’s income. See sec. 446; Petzoldt v. Commissioner, supra at 686-687. Indirect methods may be used for this purpose. Holland v. United States, 348 U.S. 121 (1954). The Commissioner’s reconstruction need only be reasonable in light of all the surrounding facts and circumstances. Petzoldt v. Commissioner, supra at 687; Giddio v. Commissioner, 54 T.C. 1530, 1533 (1970). The evidence shows that petitioner failed to provide adequate records to account for the gross receipts from her flea market sales. Therefore, it was reasonable for TCO Martin to use the cash T analysis, an indirect method, to reconstruct petitioner’s income for 2002. The cash T analysis is performed by setting up a table with income items (debits) on the left side of the “T” account and expenses (credits) on the right side of the “T” account. See, e.g., Owens v. Commissioner, T.C. Memo. 2001-143. Its purpose is “to measure a taxpayer’s reported income against personal expenditures to determine whether more was spent than wasPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011