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taxable year 2001. In the 2001 notice, respondent determined
that petitioner has unreported wage income of $30,877 for his
taxable year 2001. In the 2001 notice, respondent further
determined that petitioner is liable for that year for additions
to tax under sections 6651(a)(1) and (2) and 6654(a).
OPINION
Respondent acknowledges that section 7491(a) is applicable
in the instant case. Respondent argues, however, that petitioner
has failed to carry his burden of showing that he has satisfied
the applicable requirements of section 7491(a)(2). Consequently,
according to respondent, the burden of proof in this case does
not shift to respondent under section 7491(a). On the record
before us, we agree with respondent. We find that petitioner has
the burden of proving that the respective determinations in the
1998 notice and in the 2001 notice are wrong. Rule 142(a); Welch
v. Helvering, 290 U.S. 111, 115 (1933). That this case was
submitted under Rule 122 does not change that burden or the
effect of a failure of proof. See Rule 122(b); Borchers v.
Commissioner, 95 T.C. 82, 91 (1990), affd. 943 F.2d 22 (8th Cir.
1991).
With respect to respondent’s respective deficiency determi-
nations for the years at issue, the record establishes that
petitioner received wage income and unemployment compensation in
1998 of $15,406 and $9,375, respectively, and wage income in 2001
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