Johny L. Dotson - Page 4

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               Petitioner did not file Federal income tax returns for 1998            
          and 1999.  Respondent received information reports and prepared             
          substitutes for return for 1998 and 1999.  Respondent determined            
          that petitioner had unreported income of $15,106 and $15,962 for            
          1998 and 1999, respectively.                                                
               Section 61(a) provides that gross income includes all income           
          from whatever source derived unless excludable by a specific                
          provision of the Code.  Compensation, interest, and rents are               
          enumerated sources of income includable in gross income.  Sec.              
          61(a)(1), (4), and (5).                                                     
               Petitioner stipulated to receipt of nonemployee                        
          compensation, rent, and interest in the amounts determined in the           
          notices of deficiency.  At trial, petitioner testified that he              
          did not file Federal tax returns for 1998 and 1999.  Petitioner             
          began to make tax protester type arguments, but upon admonition             
          by the Court as to potential penalties associated with advancing            
          such arguments, petitioner concluded his testimony.  Petitioner             
          offered no evidence as to the excludability of any of the amounts           
          he received during 1998 and 1999.  We find that petitioner had              
          unreported income in 1998 and 1999 in the amounts determined by             
               We further find that respondent has satisfied his burden of            
          production with respect to the imposition of the additions to tax           
          under sections 6651(a)(1) and 6654(a).  Sec. 7491(c).                       

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