The activities of gamblers and other illegal operators have received considerable public notice recently as a result of the Kefauver Committee's investigations. Although the amounts of money involved in these operations are astronomical, no complete records are maintained by these individuals. Amounts entered on income tax returns of this type are completely incapable of verification in the usual method because of the incompleteness of the records and data available. Admittedly these operators are in the unenviable position of being required to keep complete records for income tax purposes, but being afraid to do so because of their evidentiary value to state and local authorities. However, the courts seem to have taken a lenient attitude concerning the requirements for the keeping of records as they are applied to taxpayers engaged in illegal businesses.
Note, The Income Tax and Accounting Records for Illegal Businesses, 3 Clev.-Marshall L. Rev. 54 (1954)