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section 6501 for that year had expired.
Discussion
Petitioner has introduced no credible evidence with respect
to any factual issue relevant to ascertaining whether the deter-
minations in the notice are erroneous. We find that petitioner
has the burden of proving that those determinations are wrong.
Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933); sec.
7491(a).
Petitioner proffered no evidence and advanced no argument
establishing that respondent’s determination that he had wage
income for 1997 totaling $26,690 is in error. Indeed, petitioner
concedes in the parties’ stipulation of facts in this case that
he had that amount of wage income for that year.
Nor has petitioner proffered any evidence or advanced any
argument establishing that respondent is wrong in determining
that he is liable for his taxable year 1997 for additions to tax
under sections 6651(a)(1) and 6654(a).4
We now turn to section 6673(a)(1), a provision that the
Court brought to petitioner’s attention several times both before
and during the trial in this case. The Court specifically
advised petitioner before and during trial that the questions,
4Petitioner conceded on cross-examination at trial and in
petitioner’s supplement to petitioner’s trial memorandum that he
did not file a return for his taxable year 1997. We conclude
that respondent has satisfied respondent’s burden of production
under sec. 7491(c).
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