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that a taxpayer had no unreported deductions or exclusions."
United States v. Bender, 218 F.2d 869, 871 (7th Cir. 1955).
Respondent is entitled to rely on the
presumption that the deductions and exclusions listed
by a taxpayer in his return are all that exist. This
presumption is based upon reasonable experience * * *
and has the effect of shifting the burden of going
forward with the evidence to the * * * [taxpayer], when
the Government has shown unreported income. [United
States v. Lennon, 246 F.2d 24, 27 (2d Cir. 1957)
(quoting United States v. Bender, supra at 871-872).]
In this case, Ferrentino has admitted, by filing amended
returns for the years in issue, that he had unreported income.
AJF has conceded that it should have reported the amounts earned
from delivery services for Custom Decorating. Furthermore,
respondent has shown that the fuel reimbursement check amounts
should have been included in AJF's gross income. Therefore,
since respondent has shown that petitioners had unreported
income, the burden of proving the existence of cash payments to
casual labor lies with Ferrentino.
Relying on Perez v. Commissioner, supra; Richardson v.
Commissioner, 264 F.2d 400 (4th Cir. 1959), affg. in part, revg.
in part T.C. Memo. 1958-59, and H.J. Feinberg & Co., Inc. v.
Commissioner, a Memorandum Opinion of this Court dated Sept. 20,
1950, Ferrentino argues that respondent should be required to
present affirmative evidence disputing Ferrentino's claim of
"casual labor" expenditures. In these cases, the courts
recognized that understatements of gross receipts did not
establish that a taxpayer had fraudulently intended to evade tax
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