Michael L. Goers - Page 5

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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                  

          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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