- 5 - In order to meet his burden of proof, petitioner must introduce sufficient evidence to: (1) Make a prima facie case establishing that respondent committed the errors alleged in the petition, and (2) overcome the evidence favorable to respondent. Lyon v. Commissioner, 1 B.T.A. 378, 379 (1925). Petitioner relies mainly on his testimony and certain bank statements to disprove respondent's determinations. We find this evidence unpersuasive and incomplete. We find that petitioner failed to produce any persuasive evidence rebutting respondent's determinations, and that the record is devoid of evidence otherwise disproving these determinations.1 Accordingly, we sustain respondent's determination in full. See Finesod v. Commissioner, T.C. Memo. 1994-66. For the foregoing reasons, Decision will be entered for respondent. 1We note that petitioner has also failed to address any of these determinations on brief. Petitioner was directed to file his brief with the Court in accordance with Rule 151, and he has failed to do so.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011