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to come forward with enough evidence to support a finding
contrary to the Commissioner's determination. Rockwell v.
Commissioner, 512 F.2d 882, 885 (9th Cir. 1975), affg. T.C.
Memo. 1972-133. The Court of Appeals for the Ninth Circuit has
characterized the burden of proof as a burden of persuasion.
Id.
In the case before us respondent's initial determinations,
though based upon CPI extrapolations, are entitled to the
presumption of correctness which petitioners have failed to
overcome. They have failed to introduce any reliable evidence
on the basis of which the Court could arrive at a conclusion as
to their tax liabilities different from that determined by
respondent (giving effect, of course, to certain concessions by
respondent).
The same may not be said of the increased deficiencies
asserted in the amended answer. The CPI extrapolations,
standing alone without the presumption of correctness that the
deficiency notices afford are insufficient to satisfy
respondent's burden of proof in this case. CPI extrapolations
are, almost by definition, educated guesses which respondent
may reasonably rely upon in deficiency notices under conditions
similar to those in this case, which taxpayers may refute by
introducing specific objective evidence showing the correct tax
liability. But here respondent has the burden of proof as to
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