Brandt N. Castleton - Page 19

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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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