Albert R. Cujas, Jr., & Susan W. Cujas - Page 5

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            tax on early distributions they received from their IRA's; and                               
            (2) for 1992 and 1993, petitioners were each liable for self-                                
            employment tax, additions to tax for failure to file timely                                  
            Federal income tax returns, and additions to tax for failure to                              
            make estimated tax payments.                                                                 
                  Based on the results of Agent Gardner's audit, respondent on                           
            February 29, 1996, issued a separate notice of deficiency to each                            
            I.  Unreported Income                                                                        
                  Generally, the Commissioner's determination is presumed to                             
            be correct, and the taxpayer bears the burden of proving that it                             
            is erroneous.  Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115                            
            (1933).  Some courts, however, have declined to accord a                                     
            presumption of correctness to the Commissioner's determination of                            
            unreported income where the Commissioner simply relies on the                                
            presumption without introducing sufficient evidence linking the                              
            taxpayer to an income generating activity.  Williams v.                                      
            Commissioner, 999 F.2d 760, 763 (4th Cir. 1993), affg. T.C. Memo.                            
            1992-153; Anastasato v. Commissioner, 794 F.2d 884, 886-887 (3d                              
            Cir. 1986), vacating and remanding T.C. Memo. 1985-101; Jackson                              
            v. Commissioner, 73 T.C. 394, 401 (1979).  The Commissioner need                             
            only provide a minimal amount of evidence.  Williams v.                                      
            Commissioner, supra at 766; Weimerskirch v. Commissioner, 596                                

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