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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
petitioner.
OPINION
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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