- 14 -
* * * * * * *
[6](m) Petitioner admitted in his plea agreement
that in 1996 he had income from his trade or business
of obtaining U.S. passports and of obtaining Republic
of the Marshall Island passports for various
individuals.
[6](n) Petitioner had income in 1996 from his
trade or business of obtaining legitimate U.S.
passports for residence outside of the United States,
including residence of the Marshall Islands.
In his reply to answer, petitioner states:
6(a) through (c), inclusive. Admits.
* * * * * * *
6(e). Admits.
* * * * * * *
6(m). Admits.
6(n). Admits.
Petitioner’s admissions are sufficient for respondent to carry
his initial burden of connecting petitioner with the income-
producing activity. Thus, the burden is on petitioner to show
that respondent’s deficiency determination is arbitrary or
erroneous. See Rule 142(a).
Petitioner’s argument focused exclusively on respondent’s
alleged inability to connect petitioner with the income-producing
activity. Petitioner did not produce any evidence that would
indicate respondent’s determinations were incorrect. Petitioner
has failed to meet his burden of proof. Therefore, we sustain
respondent’s determination that petitioner had unreported income
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011