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At the hearing on respondent's motion, petitioner admitted
that during 1991 he received payments in the following amounts
from the persons indicated in return for labor he performed:
Payor Amount Paid
Milton Sharp $7,795.00
Transwestern 894.73
Codega & Fricke 3,479.00
MHM, Inc. 15,790.29
Redco 15,444.03
43,403.05
Petitioner also admitted at that hearing that he did not file a
Federal income tax return for 1991.
Petitioner bears the burden of proving that respondent's
determinations in the notice are erroneous. Rule 142(a); Welch
v. Helvering, 290 U.S. 111, 115 (1933). Respondent's concession
of an error in the notice relating to the incorrect Form 1099
issued by Codega & Fricke in the amount of $6,791.10 does not
shift that burden to respondent.
Petitioner refused to enter into a stipulation of facts or
to present any evidence at trial. Except for the error alleged
in petitioner's amended petition relating to the incorrect Form
1099 issued to petitioner by Codega & Frick, the arguments he
advanced in his amended petition are tax protester type arguments
that have been repeatedly rejected by this Court and other
courts. We so found in the Order dated January 12, 1995, that we
issued with respect to respondent's motion. Nonetheless, in
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