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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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