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620 (1986) (discussing Court of Appeals for the Ninth
Circuit authorities); Tokarski v. Commissioner, 87 T.C.
74 (1986). [Fn. ref. omitted.]
The record contains ample evidence linking
petitioner both to tax-generating acts and to bank
deposits of the income generated by those acts. * * *
Once respondent has shown evidence of gross receipts, even in the
criminal or civil fraud context, petitioner has the burden of
showing offsets or deductions reducing the taxable income. See,
e.g., United States v. Shavin, 320 F.2d 308, 310-311 (7th Cir.
1963); Elwert v. United States, 231 F.2d 928, 933-936 (9th Cir.
1956); Brooks v. Commissioner, 82 T.C. 413, 433 (1984), affd.
without published opinion 772 F.2d 910 (9th Cir. 1985).
Petitioner’s obligation with respect to deductions is
indisputable. See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84
(1992); Rockwell v. Commissioner, 512 F.2d 882 (9th Cir. 1975),
affg. T.C. Memo. 1972-133. She presented no credible evidence on
any issue of fact. See sec. 7491(a). The stipulated facts
satisfy respondent’s burden of production with respect to the
penalties. See sec. 7491(c); Higbee v. Commissioner, 116 T.C.
438, 446-449 (2001).
Petitioner’s Motion to Recuse, as well as the various other
motions filed shortly before or at the calendar call, were
patently designed to delay and obstruct the determination of
petitioner’s correct tax liability. The thrust of some of
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