- 21 - List”, and petitioner has presented no evidence, and she alleges no specific instances, wherein those entities that paid income to her submitted false, fraudulent, inaccurate, or mistaken information to the Social Security Administration or the IRS. Respondent’s determinations are not arbitrary on this basis. Petitioner has failed to persuade us that respondent’s determinations are arbitrary or erroneous. Petitioner did not testify at trial, produced no evidence, called no witnesses, and has hedged her responses to respondent’s requests for admissions with her purported failed recollection of employment and receipt of income, as well as her inadequate recordkeeping. Accordingly, we sustain respondent’s determinations, and we hold that petitioner received nonemployee compensation of $7,515 in 1995 and $20,542 in 1996 from Ursuline; that she received wages of $7,347 in 1995 and $9,180 in 1997 from Ursuline and wages of $801 in 1995 and $1,335 in 1996 from the Orchestra; and that she received taxable IRA distributions of $1,140 from Bank One in 1995 and $10,750 from Pioneer in 1997. C. Additions to Tax and Penalty Section 7491(c) applies with respect to the additions to tax and the penalty in this case, since the examination commenced after July 22, 1998, the effective date of that provision. Internal Revenue Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3001(c), 112 Stat. 727. Accordingly, respondentPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011