Bruce and Judy Bailey - Page 21

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          no position that would require petitioners to present evidence              
          different from that necessary to resolve the determinations that            
          were described in the notice of deficiency, so as to justify                
          placing the burden of proof on respondent.  See Shea v.                     
          Commissioner, 112 T.C. 183 (1999).                                          
               We have considered all of the remaining arguments that have            
          been made by petitioners for a result contrary to that expressed            
          herein, and, to the extent not discussed above, they are without            
          merit.                                                                      
               To reflect the foregoing and concessions of the parties,               
                                                  Decision will be entered            
                                             under Rule 155.                          

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