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not operate a business engaged in selling jewelry and certain
other items.
We turn now to the determinations in the notice. With
respect to the determinations regarding petitioner’s Schedule C
net profit, petitioner proffered certain documentary evidence at
trial, presumably in support of his position that he does not
have the Schedule C net profit for each of the years at issue
that respondent determined in the notice. The Court allowed that
documentary evidence into the record as nothing more than peti-
tioner’s self-serving, uncorroborated, and unsubstantiated
summaries of the gross receipts and the expenses that he claims
he has for each of the years at issue. We are unwilling to rely
on those summaries. On the record before us, we find that
petitioner has failed to carry his burden of showing that respon-
dent was wrong in determining that petitioner has Schedule C net
profit for each of the years at issue in the amount that respon-
dent determined in the notice.
With respect to the determinations regarding petitioner’s
filing status, petitioner has failed to carry his burden of
showing that respondent was wrong in determining that peti-
tioner’s filing status for each of the years at issue is married
filing separately.
With respect to the determinations under section 6651(a)(1),
the matters deemed established show that petitioner did not file
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