Rita Grant Ndirika - Page 9

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          determined, inter alia, that petitioner is not entitled to                  
          exclude from her gross income any of the payments that she                  
          received during that year from GC&D, Northern Trust, and HEW FCU.           
          Respondent further determined, inter alia, that petitioner is               
          liable for additions to tax under sections 6651(a)(1) and (2) and           
          6654(a), respectively.  As discussed above, in the answer respon-           
          dent conceded the addition to tax under section 6651(a)(2).                 
                                       OPINION                                        
               Respondent concedes that section 7491 is applicable in the             
          instant case.  With respect to section 7491(a), respondent                  
          maintains that petitioner has not introduced credible evidence              
          under section 7491(a)(1) or complied with the applicable require-           
          ments of section 7491(a)(2).  Therefore, according to respondent,           
          the burden of proof with respect to respondent’s deficiency                 
          determination for petitioner’s taxable year 2000 does not shift             
          to respondent.  On the record before us, we find that petitioner            
          has failed to carry her burden of establishing that she has                 
          complied with the applicable requirements of section 7491(a)(2).            
          On that record, we further find that petitioner has not intro-              
          duced credible evidence with respect to any factual issue rele-             
          vant to the Court’s determining whether to sustain respondent’s             
          deficiency determination at issue.  On the record before us, we             
          conclude that petitioner has the burden of proving that that                
          determination is wrong.  See Rule 142(a); Welch v. Helvering, 290           






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