Gregory Harris Sims - Page 5

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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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