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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 a
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