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to recharacterize any of the original deductions. Sec. 6001;
sec. 1.6001-1(a), (e), Income Tax Regs.3
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
3In the absence of substantiation or credible evidence
regarding this issue, the burden of proof remains on petitioner
to show the existence of the business and his entitlement to the
deductions. Sec. 7491(a); Rule 142(a).
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Last modified: May 25, 2011