Diana Cote - Page 5

          deficiency is presumptively correct once some substantive                   
          evidence is introduced demonstrating that the taxpayer received             
          unreported income).  McManus v. Commissioner, T.C. Memo. 2006-57;           
          see also Palmer v. United States, 116 F.3d 1309, 1312 (9th Cir.             
          1997) (“The Commissioner’s deficiency determinations and                    
          assessments for unpaid taxes are normally entitled to a                     
          presumption of correctness so long as they are supported by a               
          minimal factual foundation.”).  If the Commissioner introduces              
          some evidence that the taxpayer received unreported income, the             
          burden shifts to the taxpayer to show by a preponderance of the             
          evidence that the deficiency was arbitrary or erroneous.  Hardy             
          v. Commissioner, 181 F.3d 1002, 1004 (9th Cir. 1999), affg. T.C.            
          Memo. 1997-97.                                                              
               We conclude that respondent has shown a sufficient                     
          evidentiary foundation as to the unreported income determined in            
          the notice of deficiency.  Respondent has introduced, and we have           
          admitted, into evidence certified transcripts listing the amount            
          of income that third parties have represented to respondent as              
          having been paid to petitioner, and petitioner makes no challenge           
          to the accuracy of these transcripts.  See Green v. Commissioner,           
          T.C. Memo. 1996-107, affd without published opinion 113 F.3d 1251           
          (11th Cir. 1997).  Respondent also has introduced, and we have              
          admitted, into evidence records of OppenheimerFunds Services and            
          Franklin Templeton Investor Services.  The records show that                

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