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II. Returns
Petitioner hired certified public accountants and provided
them with the information to prepare his returns. On October 15,
1995, petitioner’s 1994 return was due (i.e., after extensions).
On November 22, 1997, petitioner signed his 1994 return. In a
letter dated July 15, 1998, respondent stated that he was
beginning to examine the 1994 return.
On October 15, 1996, petitioner’s 1995 return was due (i.e.,
after extensions). On November 22, 1996, respondent received the
1995 return. Petitioner filed his 1996 return in a timely
manner. In a letter dated February 11, 1999, respondent stated
that he was beginning to examine petitioner’s 1995 and 1996
returns.
OPINION
Petitioner contends that he is entitled to all of the
deductions shown on his returns. Respondent contends that
petitioner is entitled only to the deductions conceded by
respondent.
I. Burden of Proof and Production
Section 7491(a)(1), relating to examinations commenced after
July 22, 1998, provides that if, “in any court proceeding, a
taxpayer introduces credible evidence with respect to any factual
issue relevant to ascertaining the liability of the taxpayer for
any tax * * * the Secretary shall have the burden of proof with
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