- 4 -
Respondent's revenue agent, Shelby Bare, testified that
respondent relied upon payer information returns which were
received under the Information Returns Program (IRP) in making
the determinations contained in the statutory notices of
deficiency issued to petitioner in this case. Respondent
submitted transcripts from his IRP master file which list the
payers which reported payments to petitioner during 1987 and
1988.
At trial, petitioner failed to submit any credible evidence
into the record. Cf. sec. 6201(d). He presented no documents
and the following is the extent of his testimony:
The Court: State your name for the record, please.
Petitioner: Ross William Bruner.
The Court: And your current address?
Petitioner: I live at 5 East Cairo, Tempe, Arizona.
The Court: Very well. What did [sic] you have to say
now to convince the Court that the contents
of the statutory notice of deficiency are in
error, Mr. Bruner?
Petitioner: I have never received income, therefore, I
stand in silence.
In response to numerous questions by respondent's counsel,
petitioner declined to offer any testimony relevant to the
determination of his income for 1987 and 1988. His response to
each question was "I stand in silence."
Based on the record, we find that petitioner has failed to
meet his burden of proving any error in respondent's
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011