- 7 -
Commissioner, 85 T.C. 527, 529 (1985); Jacklin v. Commissioner,
79 T.C. 340, 344 (1982).
The burden of proof is on petitioner to establish that the
determinations in the notice are erroneous. Rule 142(a); Welch
v. Helvering, 290 U.S. 111, 115 (1933).
Petitioner is deemed to have admitted that he received the
wage, self-employment, and interest income determined in the
notice. Petitioner is also deemed to have admitted that he
failed to file a return for 1991 and that that failure was
because of willful neglect. Based on the deemed admissions in
this case, and taking account of petitioner's failure to set
forth facts showing that he is entitled to any deductions or
exemptions other than those allowed in the notice, we conclude
that respondent has satisfied her burden of proving that no
genuine issue of material fact exists as to respondent's determi-
nations for 1991 and that respondent is entitled as a matter of
law to a decision thereon. Accordingly, we shall grant respon-
dent's motion. Rule 121; Marshall v. Commissioner, supra at 272.
To reflect the foregoing,
An appropriate order granting
respondent's motion for summary
judgment and decision will be
entered for respondent.
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