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87 T.C. 74, 76-77 (1986). Therefore, petitioner bears the burden
of proving that respondent's determination of deficiencies is
erroneous. Rule 142(a).
II. Deficiencies in Tax
Petitioner assigns error to respondent’s determination of
deficiencies in tax on the grounds that respondent failed to
consider the nontaxable sources of the amounts expended for the
listed property.
In 1989, petitioner was adjudged guilty of money laundering
and conspiracy to distribute cocaine. At petitioner’s
rearraignment on the charges that led to that judgment, the
District Court was presented with the plea agreement and
statement of facts, in which (when taken together) it is stated
that petitioner had received illegal earnings from trafficking in
cocaine, which were expended for certain property, including the
listed property. During his rearraignment hearing, petitioner
agreed that the plea agreement and the statement of facts were
correct. In this Court, however, petitioner asks us not to
credit the plea agreement and statement of facts, claiming that
he entered into the plea agreement and agreed that the plea
agreement and statement of facts were correct only to please the
Government and to avoid further prosecution. He further claims
that he earned no cash income from drug sales, being paid for his
drug-connected activities in drugs that he consumed, and that the
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