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circuit to which an appeal of this case lies, provides that “the
burden [in such a case] shifts to the government to prove the
correct amount of any taxes owed.” Portillo v. Commissioner,
932 F.2d 1128, 1133 (5th Cir. 1991), affg. in part, revg. in
part, and remanding T.C. Memo. 1990-68; Carson v. United States,
560 F.2d 693, 696 (5th Cir. 1977).
As to the wage income, we believe that respondent’s
calculation of Mr. Burnett’s wage income for 1994 stands on solid
ground and is neither arbitrary nor erroneous. First, the
parties have stipulated (and we have found as a fact) that Mr.
Burnett was employed by and received wages from Lubbock during
1994. Second, respondent derived the $19,913 from his master
file transcript that indicated that Lubbock had issued to Mr.
Burnett a Form W-2, Wage and Tax Statement, reporting that it had
paid to him during 1994 wages of that amount. Third, respondent
requested and received supporting documentation from Lubbock
which indicated that it had paid to Mr. Burnett during 1994 that
amount of wages. Whereas petitioners ask the Court to find that
Lubbock paid Mr. Burnett only $16,177 of wages during 1994, i.e.,
the amount that he received during the 1993/1994 school year, the
record disproves such a finding. The record indicates (and we
have found as a fact) that Lubbock paid to Mr. Burnett wages
after the 1993/1994 school year. We sustain respondent’s
determination as to the unreported wages. In so doing, we note
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