context: This provision, by granting the IRS assessment authority, must simultaneously grant the IRS power to decide how to make that assessment -- at least within certain limits. And the courts have consistently held that those limits are not exceeded when the IRS estimates an individual's tax liability -- as long as the method used to make the estimate is a "reasonable" one.
citation_a.signal: see also
citation_a.identifier: 552 F. 2d 549, 551-552
citation_a.parenthetical: upholding estimate using extrapolation of income over 1-year period based on gross receipts from two days
citation_a.sentence: See also Janis, supra, at 437 (upholding estimate of tax liability over 77-day period made by extrapolating information based on gross proceeds from 5-day period); Dodge v. Commissioner, 981 F. 2d 350, 353-354 (CA8 1992) (upholding estimate using bank deposits by taxpayer); Pollard v. Commissioner, 786 F. 2d 1063, 1066 (CA11 1986) (upholding estimate using statistical tables reflecting cost of living where taxpayer lived); Gerardo v. Commissioner, 552 F. 2d 549, 551-552 (CA3 1977) (upholding estimate using extrapolation of income over 1-year period based on gross receipts from two days); Mendelson v. Commissioner, 305 F. 2d 519, 521-522 (CA7 1962) (upholding estimate of waitress’ tip income based on restaurant’s gross receipts and average tips earned by all wait resses employed by restaurant); McQuatters v. Commissioner, 32 TCM 1122 (1973), ¶ 73,240 P-H Memo TC (same).
citation_b.signal: see
citation_b.identifier: 937 F. 2d 1548, 1551
citation_b.parenthetical: estimate made with reference to taxpayer's purchasing record was "presumptively correct" when based on "reasonable foundation"
citation_b.sentence: See, e. g., Erickson v. Commissioner, 937 F. 2d 1548, 1551 (CA10 1991) (estimate made with reference to taxpayer’s purchasing record was “presumptively correct” when based on “reasonable foundation”).