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respondent's responsibility to show that petitioners received an
item of income, were not entitled to a deduction, or are subject
to the additions to tax. That, of course, is not so. See Rule
142(a). Walter has had legal training. He was advised by the
Court to pay close attention to our Rules. At various times,
both the Court and respondent's counsel have tried to give
petitioners, who represent themselves, help in understanding and
complying with the procedures and formalities for preparing,
trying, and briefing their case. We cannot, and will not,
however, excuse or overlook petitioners' failure to abide by our
Rules or to understand some of the basic and fundamental aspects
of bringing a case in the Tax Court. Petitioners' apparent
failure to understand their obligation to prove their case
imposes risks that they must bear.
Income Items in Dispute
The parties have stipulated to, or conceded at trial or on
brief, numerous issues that relate to respondent's bank deposit
analysis. The parties have stipulated to the amounts that are in
dispute under respondent's bank deposit analysis. They have
prepared an exhibit (Exhibit 201-GK) setting forth those amounts
and certain other amounts that were not deposited in any bank
account but that are in dispute between the parties. We have
reproduced Exhibit 201-GK as an appendix. We accept that the
items on Exhibit 201-GK are the remaining items of income that
are in dispute and that we must determine. We have grouped those
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