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need only be minimal. Weimerskirch v. Commissioner, 596 F.2d
358, 361 (9th Cir. 1979), revg. 67 T.C. 672 (1977).
Petitioner's primary contention is that respondent has the
burden of proof in this case because it involves an under-
reporting of income. However, as previously discussed, respon-
dent has successfully linked petitioner to several income-
generating activities. Therefore, the burden of proof rests
squarely with petitioner. Petitioner's testimony at trial was
vague, diffuse, and did not address the factual issues in
dispute. We conclude petitioner has not produced sufficient
evidence to carry his burden of proof. Accordingly, we sustain
respondent's notice of deficiency with respect to the unreported
income.
Respondent determined that petitioner was liable for self-
employment taxes under section 1401. On brief, petitioner failed
to address this issue. We treat this failure as, in effect, a
concession by petitioner. See subparagraphs (4) and (5) of Rule
151(e); Money v. Commissioner, 89 T.C. 46, 48 (1987).
Respondent also determined that petitioner was entitled to
the standard deduction and exemptions for himself and his wife.
The BLS table that respondent used to determine petitioner's
income indicates that the average family unit contains a child
under the age of 18. Under these circumstances, we are persuaded
that respondent should have allowed petitioner an additional
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