Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 9

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          received a $1,000 cleaning deposit from the Barretts in that                
          year.  The Dickersons received payments from the Barretts with              
          regard to the lease of the Green Ridge residence in the amount of           
          $850 each on August 20, 1990, September 20, 1990, and October 30,           
          1990.  The Dickersons never lived at the Green Ridge residence.             
          The Dickersons presented no arguments why this amount should not            
          be included in income.  We therefore consider this issue to be              
          abandoned and sustain respondent on this issue.  See Lime Cola              
          Co. v. Commissioner, 22 T.C. 593, 606 (1954).                               
          Unreported Income--General                                                  
               Respondent, using a bank deposits and expenditures analysis,           
          determined that each of the petitioners had unreported income for           
          some of the years in issue.                                                 
               The United States Court of Appeals for the Ninth Circuit, to           
          which an appeal of this case would lie, has held that in order              
          for the presumption of correctness to attach to the notice of               
          deficiency in unreported income cases, the Commissioner must come           
          forward with substantive evidence establishing “some evidentiary            
          foundation” linking the taxpayer to the income-producing                    
          activity, Weimerskirch v. Commissioner, supra at 361-362, or                
          “demonstrating that the taxpayer received unreported income”,               
          Edwards v. Commissioner, 680 F.2d at 1270; see also Rapp v.                 
          Commissioner, 774 F.2d 932, 935 (9th Cir. 1985), affg. an Order             
          of this Court.  We must examine the record to determine whether             
          there is a minimal evidentiary foundation supporting respondent's           

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