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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
respondent.
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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