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look to Karme v. Commissioner, 673 F.2d at 1065, for guidance as
to the purpose served by such a minimal evidentiary foundation:
“the taxpayer may face practical difficulties in attempting to
refute the Commissioner’s assertion that the taxpayer received
unreported income.” By the time this case came to trial (indeed
upon receipt of the notices of deficiency), petitioner was
informed that respondent had determined that petitioner had
unreported income from real estate, the addresses of the real
estate in question, the amounts of the omitted income, and the
sources of respondent’s information. Petitioner faced no
practical difficulties in determining precisely what she had to
prove to sustain her assignment of error that “more income than I
earned was attributed to me”. She had to prove that she did not
own the specific properties in question, did not receive rents in
the amounts alleged, or had deductions greater than had been
allowed. True, respondent introduced no third-party records
substantiating his claims that petitioner owned rental properties
and received rents from them. We assume that the reason he did
not, however, was that in the petition, petitioner did not aver
that respondent had failed to link her to an income-producing
activity. The situation here is the same as in Rapp v.
Commissioner, 774 F.2d 932 (9th Cir. 1985), where the
Commissioner did not introduce underlying third-party records,
but the Court of Appeals allowed the Commissioner to rely on the
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