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may be simply put: a court is given sufficient cause to set aside
respondent’s determination of a deficiency if it is shown to the
court that such determination was arbitrarily made. Helvering v.
Taylor, supra at 515.
Petitioner has the burden of proving the arbitrariness of
respondent’s deficiencies, Williams v. Commissioner, 999 F.2d
760, 763 (4th Cir. 1993), affg. T.C. Memo. 1992-153; Shriver v.
Commissioner, 85 T.C. 1, 3 (1985). The statutory notice, which
is in evidence, states that, in various amounts, for the various
years here in issue, petitioner had unreported income from self-
employment, rentals, bartering transactions, wages, capital
gains, and interest. The statutory notice allows various
deductions. Petitioner has produced no evidence that any of the
deficiencies in question were arbitrarily and erroneously
determined. Petitioner principally relies on her own testimony
and unsupported statements on brief that, during the years in
question, she did not work, had no bartering income, lost money
on her rental real estate properties, lived with a "significant
other", and existed on gifts from her parents. First, we do not
believe much of what petitioner claims. There is convincing
evidence that petitioner had items of income from real estate
sales, brokerage activities, and other sources during the years
in issue. Second, petitioner was not a credible witness. On
cross-examination, petitioner was unable to explain why a check
she claimed as child support carried the notation “Cash for
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