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under section 7491(a), respondent maintains that that burden has
not shifted. That is because, according to respondent, peti-
tioner failed to comply with section 7491(a)(2)(A) and (B).
Petitioner takes no position as to whether his burden of proof
has shifted to respondent under section 7491(a) with respect to
the determinations in question. We conclude that resolution of
those determinations does not depend on who has the burden of
proof with respect to them. We now turn to those determinations.
Petitioner acknowledges (1) that he has net profit for 1996
and 1997 from his washing machine repair business in the amounts
of $30,2014 and $30,227,5 respectively, and (2) that he has
pension income for 1997 of $3,852. However, it is petitioner’s
position that neither his net income for each of the years at
issue from his washing machine repair business nor his pension
income for 1997 is subject to tax.
In support of his position with respect to his net profit
for each of the years at issue from his washing machine repair
business, petitioner argues, inter alia, that that profit was
“directly derived from the exchange of Petitioner’s personal
4Petitioner rounded his net profit for 1996 from his washing
machine repair business to $30,201. According to the parties’
stipulation of settled issues, the actual net profit for 1996
from that business is $30,200.31.
5Petitioner rounded his net profit for 1997 from his washing
machine repair business to $30,227. According to the parties’
stipulation of settled issues, the actual net profit for 1997
from that business is $30,227.02.
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