- 13 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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