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Revenue Agent Laakso, we conclude that respondent has met his
burden of production pursuant to section 7491(c) regarding this
issue. Thus, petitioner must come forward with evidence
sufficient to persuade the Court that respondent’s determination
is incorrect or that an exception applies. Rule 142(a); Welch v.
Helvering, 290 U.S. at 115; see Higbee v. Commissioner, supra at
447.
Petitioner failed to appear and did not introduce any
evidence. Accordingly, on this issue, we sustain respondent’s
determination.
C. Conclusion
We have sustained all of respondent's determinations.
Therefore, we will dismiss the case and enter a decision against
petitioner. Rules 123(b), 142(a); Welch v. Helvering, supra at
115.
To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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