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to adequately explain why he either did not visit them in the 3
years he was allegedly receiving income from them through Mr.
Tomlin, or why he was unconcerned that he was unable to locate
these corporations. Finally, petitioner did not present evidence
of any services which he had performed, such as the architectural
drawings involved.
Because petitioner has failed to establish he had earned
income in any of the years in issue, we uphold respondent’s
determination that petitioner is not entitled to the earned
income credit for each year.
To reflect the foregoing,
Decisions will be entered
for respondent in the amounts of
the reduced deficiencies.
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Last modified: May 25, 2011