-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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