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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.
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Last modified: May 25, 2011