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Commissioner, 43 T.C. 824, 831 (1965).2 Petitioner argues that
the notices of deficiency in this case were arbitrary and
erroneous, in which case they would not be entitled to the
presumption of correctness ordinarily accorded to deficiency
notices. Pittman v. Commissioner, 100 F.3d 1308, 1317 (7th Cir.
1996), affg. T.C. Memo. 1995-243. We disagree with respect to
the notices of deficiency for every year in issue except 1993.
For each of the years in issue except 1992, respondent
determined that petitioner had (i) specific items of income from
identified sources, based on information reported by third
parties on Forms W-2 or Forms 1099; and (ii) a specified amount
of "unreported income". The notice for 1992 determined only
"unreported income" and did not determine any income from
identified sources. For each item of income from identified
sources, the notice provided an explanation of the source. The
"unreported income" item was explained in each of the notices as
follows: "We have computed your unreported taxable income using
reasonable estimates based on known sources of income and
2 Petitioner contends that he had maintained records of his
business operations but that they were lost in a flood at his
residence in July 1996. Petitioner has offered no corroborating
evidence of this contention, and we reject it as unsubstantiated.
Petitioner provided noncredible or contradictory testimony with
respect to other important aspects of this case. For example, he
contended that he did not earn more than $5,535 in 1990, despite
representing in a prior court proceeding that his annual income
at this time was $18,000. Moreover, although he testified that
he had submitted a claim regarding the flood damage with the
Federal Emergency Management Agency, he produced no documentary
evidence of such claim.
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