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produce the required appraisal.
Because petitioner failed to substantiate his 1999
charitable contributions, we sustain respondent’s determination
disallowing petitioner’s 1999 charitable contribution deduction.
2. Unreported Income
The Commissioner’s deficiency determination is normally
entitled to a presumption of correctness, Rapp v. Commissioner,
774 F.2d 932, 935 (9th Cir. 1985), and the burden of proving the
determination incorrect generally rests with the taxpayer, Rule
142(a). However, when a case involves unreported income and that
case is appealable to the Court of Appeals for the Ninth Circuit,
barring a stipulation to the contrary, the Commissioner’s
determination of unreported income is entitled to the presumption
of correctness only if the determination is supported by some
evidence linking the taxpayer to an income-producing activity.
Palmer v. United States, 116 F.3d 1309, 1313 (9th Cir. 1997).
Once the Commissioner produces evidence linking the taxpayer to an
income-producing activity, the burden shifts to the taxpayer to
rebut the presumption by establishing that the Commissioner’s
determination is arbitrary or erroneous. Rapp v. Commissioner,
supra at 935; Adamson v. Commissioner, 745 F.2d 541, 547 (9th Cir.
1984), affg. T.C. Memo. 1982-371; see also United States v. Janis,
428 U.S. 433, 441-442 (1976).
This case is appealable, barring a stipulation to the
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