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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, respondent
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