§5324

5324(a)(3) and (d)(1). Petitioner was sentenced to 33 months in prison and, inter alia, ordered to pay tax restitution of$264,335 to the United States pursuant to the terms of 18 U.S.C. sec. 3612(f)(3)(A). Petitioner makes his views clear on the first page ofhis petition, wherein he states: [t]his Notice [ofdeficiency] shows an adjustment to a

5324(3) (1994), in connection with the purchase of 13 cashier’s checks between August 24, 1990, and January 16, 1991. - 12 - He pleaded guilty to each, in connection with which he admitted the following: I provided my accountant with false information regarding my 1987 income which caused him to prepare a false return that substantially under

section 5324(3) (1988). The civil forfeiture of petitioner's accounts was pursuant to 18 U.S.C. section 981 (1988 and Supp. II 1990) which provides that "Any property, real or personal, involved in a transaction or attempted transaction in violation of 5313(a) or 5234 of title 31, * * * , or any property - 6 - traceable to such property" is subjec

OPINION Petitioner has the burden of showing that respondent's determinations in the notice for 1986 that remain at issue are - 9 - erroneous.6 Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Unreported Income Section 6001 requires taxpayers to maintain sufficient records to determine their correct tax liabilities.