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There is ample evidence linking petitioner to income-
producing activities. He received nonemployee compensation from
Wendell Builders, Inc., Walker Custom Homes, and Paul
Development, Inc., and Social Security benefits. At trial,
respondent submitted Forms 1099-MISC, Miscellaneous Income, a
certified transcript from the Social Security Administration,
nonemployee compensation payor records, and declarations under
penalties of perjury of those payors as to the validity of these
underlying documents. The transcripts, declarations, and
supporting documents show that petitioner received income during
the years in issue. Thus, petitioner bears the burden of proving
respondent’s determinations are in error. See Edwards v.
Commissioner, supra; Weimerskirch v. Commissioner, supra.
2. Burden of Proof
Respondent bears the burden of proving the increased
addition to tax raised in the pleadings. See Rule 142(a). This
increase is computational.
Petitioner contends that respondent generally bears the
burden of proof. We disagree. The burden of proof for a factual
issue relating to liability for tax may shift to the Commissioner
under certain circumstances. Sec. 7491(a). Under section
7491(a), the burden of proof with respect to a factual issue
relevant to a taxpayer’s liability for tax shifts from the
taxpayer to the Commissioner if, inter alia, the taxpayer has:
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