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respondent’s reasonable requests. For similar reasons, section
6201(d) does not apply to place on respondent the burden of
producing evidence to supplement the information returns. See
McQuatters v. Commissioner, T.C. Memo. 1998-88.
A. Income From Compton Unified
Petitioner began working as a math and science teacher for
Compton Unified in September 1995. Sometime about February 15,
1996, petitioner was injured during an altercation with a student
while teaching at Whaley Middle School. Petitioner suffered a
back injury and was unable to teach his classes for the remainder
of the spring 1996 school term. Petitioner was granted
“industrial accident leave” from February 16 until June 12, 1996,
and continued to receive his full salary.
Petitioner returned to teaching in September 1996 for the
beginning of the 1996-97 school year. Due to continuing concerns
over his health, petitioner returned as a substitute teacher on a
temporary contract and was assigned to the district’s substitute
pool. Certified quarterly earnings reports prepared by Compton
Unified reflect that petitioner received a monthly salary of
$2,626.81 from January 1997 through June 1997 and $2,895.77 for
September 1997 through December 1997.4 Compton Unified’s
4 No Federal income taxes were withheld from petitioner’s
salary during this time. Compton Unified’s payroll administrator
testified that petitioner was classified as an “exempt
individual”, but did not further explain the basis for the
(continued...)
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