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the presumption of correctness, unless there is some
reasonable foundation for the determination. E.g.,
Erickson v. Commissioner, 937 F.2d 1548, 1551 (10th Cir.
1991), affg. T.C. Memo. 1989-552; Rapp v. Commissioner,
supra at 935; Llorente v. Commissioner, supra at 156;
Weimerskirch v. Commissioner, supra at 360-361. The
reasonable foundation may consist of evidence linking the
taxpayer with an income-producing activity such that it can
be inferred that the taxpayer received income from the
activity, see, e.g., Weimerskirch v. Commissioner, supra
at 360, or it may consist of evidence showing an ownership
interest in assets possessed by the taxpayer, see, e.g.,
Erickson v. Commissioner, supra at 1551-1552. Once the
Commissioner has demonstrated sufficient minimal facts to
link the taxpayer with an income-producing activity or
to show an ownership interest in assets possessed by the
taxpayer, the presumption of correctness arises, and the
taxpayer has the burden to rebut the presumption by
establishing by a preponderance of the evidence that any
deficiency determination is arbitrary or erroneous. See
Erickson v. Commissioner, supra at 1551-1552; Rapp v.
Commissioner, supra; Petzoldt v. Commissioner, supra at
689.
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