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received self-employment income in 1993 and 1994. See, e.g.,
Senter v. Commissioner, T.C. Memo. 1995-311 (concluding that
respondent failed to provide predicate evidence to support her
deficiency determinations based on CPI calculations). Therefore,
respondent has the burden of coming forward with evidence to
establish the existence and amount of any deficiency. See
Jackson v. Commissioner, 73 T.C. 394, 401 (1979). Respondent
failed to present any evidence relating to these determinations.
Accordingly, we do not sustain respondent’s determinations
relating to petitioner’s income and self-employment tax
deficiencies relating to 1993 and 1994.
II. Additions to Tax
Respondent determined that petitioner is liable, pursuant to
sections 6651(a) and 6654, for additions to tax for failure to
file timely Federal income tax returns and to make estimated tax
payments, respectively, relating to the years in issue.
Petitioner failed to present any evidence relating to these
issues. Accordingly, we sustain respondent’s determinations.
Contentions we have not addressed are irrelevant or
meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011