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sources in amounts at least as great as determined in the notice
of deficiency.7
Because petitioner has not established error in the
deficiency determinations contained in the notice of deficiency,
we sustain these determinations.
C. Asserted Increases in Deficiencies
By amended answer, respondent asserted increases in
petitioner’s deficiencies attributable to unreported nonemployee
compensation of $24,000 and $22,400 for 1995 and 1996,
respectively, that petitioner allegedly received from the
Louisville Chorus. Respondent bears the burden of proof with
respect to these asserted increases in deficiencies. Rule
142(a).
7 On brief, petitioner cites Portillo v. Commissioner, 932
F.2d 1128 (5th Cir. 1991), affg. in part, revg. in part and
remanding T.C. Memo. 1990-68, in support of his contention that
respondent acted improperly in relying upon third-party payment
reports. We construe petitioner’s argument to be that respondent
was required to make an independent investigation of the third-
party payment reports before relying upon them. Such an argument
is without merit. Petitioner never filed a Form 1040, U.S.
Individual Income Tax Return, or any other document in which he
swore that he did not receive the reported income, nor has
petitioner otherwise raised any reasonable dispute about the
third-party payment reports. Accordingly, respondent had no duty
to investigate the third-party payment reports. See Parker v.
Commissioner, 117 F.3d 785, 787 (5th Cir. 1997), affg. an order
of this Court; Andrews v. Commissioner, T.C. Memo. 1998-316. For
similar reasons, plus the additional reason that petitioner has
not fully cooperated with respondent in providing relevant
information, the provisions of sec. 6201(d) are inapplicable.
See Spurlock v. Commissioner, T.C. Memo. 2003-124.
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