- 19 - compensation for services received from RRS in 1999. Although the evidence summarized above is sufficient to satisfy respondent’s initial burden of production, we are not convinced that respondent’s income adjustment should be sustained. The letters on which respondent relies to estimate the compensation petitioner received are unclear at best and seem to reflect that petitioner contributed equipment and services to RRS, which RRS then transferred to unnamed third parties for a fee. It does not appear that petitioner kept any of the funds, even if he received them. Moreover, the amount of the 1999 income adjustment is an estimate drawn from less than clear correspondence, and we are not convinced that the estimate is reliable. Finally, although we acknowledge that petitioner is deemed to have admitted he received compensation for personal services provided to RRS in 1999, the deemed admission does not establish the identity of the payor or the amount of the compensation paid. Because the record causes us to doubt that respondent’s estimate of petitioner’s compensation is reliable or correct, we do not sustain respondent’s determination that petitioner had unreported income attributable to services he rendered to RRS in 1999. 3. Child Tax Credit Section 24(a) provides for a credit against tax for each qualifying child of the taxpayer. Section 24(c)(1) defines aPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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