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reasonably relied on the information received from third parties
that payments had been made to petitioner. Petitioner did not
file a return or any other document under oath that contradicted
the information return material from third parties. Petitioner
also admits that he received “compensation for labor”. The
determination that the amounts received were income to petitioner
placed the burden on petitioner to show that the amounts reported
to respondent were in error or were not income.
Petitioner, during trial, did not agree that the amounts
reported by the third parties were correct, but he did not offer
any evidence to show that the information relied upon by
respondent was in error. Petitioner tacitly accepted that he
received some amounts from others, but he did not agree that any
amounts received were taxable income. Instead, he argued that
compensation for his labor does not constitute taxable income, a
position that is frivolous.
The remaining arguments and points made by petitioner are
either incomprehensible or not worthy of comment. Therefore, we
hold that petitioner has not shown that respondent’s
determination that petitioner failed to report income is in
error.
2(...continued)
in this case began prior to July 22, 1998. IRS Restructuring and
Reform Act of 1998, Pub. L. 105-206, 112 Stat. 726.
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