- 5 - 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.Page: Previous 1 2 3 4 5 6 Next
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