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deficiency determination is normally entitled to a presumption of
correctness. Rapp v. Commissioner, 774 F.2d 932, 935 (9th Cir.
1985); Delaney v. Commissioner, 743 F.2d 670, 671 (9th Cir.
1984), affg. T.C. Memo. 1982-666; Weimerskirch v. Commissioner,
596 F.2d 358, 360 (9th Cir. 1979), revg. 67 T.C. 672 (1977); see
Rule 142(a); see also Welch v. Helvering, 290 U.S. 111, 115
(1933). However, in an unreported income case this presumption
arises only when it is supported by some substantive evidence
that the taxpayer received unreported income. Rapp v.
Commissioner, supra; Delaney v. Commissioner, supra; Weimerskirch
v. Commissioner, supra; see also United States v. Janis, 428 U.S.
433, 441-442 (1976). Once the Commissioner has carried his
initial burden of introducing some evidence linking the taxpayer
with the income-producing activity, the burden shifts to the
taxpayer to rebut the presumption by establishing by a
preponderance of the evidence that the deficiency determination
is arbitrary or erroneous. Rapp v. Commissioner, supra; Adamson
v. Commissioner, 745 F.2d 541, 671 (9th Cir. 1984), affg. T.C.
Memo. 1982-371; see Rule 142(a).
In his answer, respondent states:
[6](c) In this plea agreement, petitioner admitted
he had gross income during the calendar year 1996 of at
least $645,253.00.
* * * * * * *
[6](e) During 1996 the petitioner was in the trade
or business of obtaining passports and visas.
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