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received unreported income, Edwards v. Commissioner, 680 F.2d
1268, 1270 (9th Cir. 1982); see Petzoldt v. Commissioner, 92 T.C.
661, 689 (1989).
There is an evidentiary foundation connecting petitioner
with an income-producing activity. The Court finds that
petitioner was an insurance agent during the years at issue and
received commission income from insurance companies.
Petitioner bears the burden of proving that respondent’s
determinations are incorrect. See Rule 142(a). Petitioner
provided no evidence to dispute respondent’s determination of
petitioner’s receipt of income for the years at issue.
Therefore, the Court concludes petitioner received taxable income
of $113,469 and $68,233 in 2001 and 2002, respectively.
C. Additions to Tax
Pursuant to section 7491(c), the Commissioner has the burden
of production with respect to any penalty, addition to tax, or
additional amounts. The burden of production requires the
Commissioner only to come forward with sufficient evidence
indicating it is appropriate to impose additions to tax. Higbee
v. Commissioner, 116 T.C. 438, 446 (2001).
Petitioner did not file returns for the years at issue, and
he did not make estimated tax payments with respect to his tax
liabilities for those years. There is no evidence that
petitioner paid any tax for the years at issue. Thus, respondent
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