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burden rests with petitioners to demonstrate that respondent's
determinations are erroneous. Rule 142(a).
A rare exception to this rule is where the Commissioner, in
a case involving unreported income, introduces no evidence but
rests on the presumption of correctness and the taxpayer
challenges the deficiency on the grounds that it is arbitrary.
Schad v. Commissioner, 87 T.C. 609, 618 (1986), affd. without
published opinion 827 F.2d 774 (11th Cir. 1987). The
Commissioner in these circumstances must show some minimal
evidentiary foundation connecting the taxpayer to an income-
producing activity or to the funds. Edwards v. Commissioner, 680
F.2d 1268, 1270 (9th Cir. 1982), affg. an Order of this Court;
Weimerskirch v. Commissioner, 596 F.2d 358, 361-362 (9th. Cir.
1979), revg. 67 T.C. 672 (1977). Whether or not respondent has
substantiated her determination of unreported income with this
evidentiary foundation will be discussed as the issue is
addressed for each petitioner.
Petitioners in these cases rely heavily on their own
testimony. We found some of petitioners' testimony to be
general, vague, conclusory, and/or questionable in certain
material respects. Under the circumstances presented here, we
are not required to, and generally do not, rely on petitioners'
testimony to sustain their burden of establishing error in
respondent's determinations. See Lerch v. Commissioner, 877 F.2d
624, 631-632 (7th Cir. 1989), affg. T.C. Memo. 1987-295; Geiger
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