Ross William Bruner - Page 4

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               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                        




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