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$22,500 in 1992 and $28,200 in 1993. There is no documentary
evidence to corroborate this testimony.
Petitioners cite two documents: "QNC Contribution
Instructions", which Mr. Fox signed on December 30, 1992, states:
"Contribution amount $100,000"; and "Collateralized Personal Line
of Credit Instructions", which Mr. Fox signed on December 30,
1992, states: "Amount to be wired $85,000". These documents do
not show that petitioners paid $100,000 in 1992 or at any time.
We conclude that petitioners may not deduct $100,000 in 1992
under section 419.
D. Whether Mr. and Mrs. Fox Had $2,237 in Unreported Interest
Income
Respondent determined and contends that Mr. and Mrs. Fox had
$2,237 in unreported interest income from Oxyfresh in 1993.
Neither party offered any evidence on this issue. Petitioners
contend that respondent has the burden of producing evidence
linking them to the unreported income, Weimerskirch v.
Commissioner, 596 F.2d 358, 360 (9th Cir. 1979), revg. 67 T.C.
672 (1977), and that respondent failed to do so. We agree with
petitioners.
The U.S. Court of Appeals for the Ninth Circuit, the circuit
in which this case is appealable, requires the Commissioner to
introduce some substantive evidence that shows that the taxpayer
received unreported income. United States v. Zolla, 724 F.2d 808
(9th Cir. 1984); Weimerskirch v. Commissioner, supra. Oxyfresh
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