Norman W. Klootwyk - Page 3

          year.  In a notice of deficiency dated January 28, 2004,                    
          respondent determined the above-stated deficiency and additions             
          to tax.  Petitioner timely filed a petition disputing the                   
               Petitioner did not submit a pretrial memorandum as required            
          by the Court’s standing pretrial order.  At calendar call,                  
          petitioner did not appear, but the Court had before it and                  
          granted petitioner’s motion for a trial time and date certain.              
          At trial, petitioner did not personally appear but was                      
          represented by counsel.  Petitioner’s counsel did not introduce             
          any evidence on petitioner’s behalf at trial and failed to file             
          an opening brief following the trial.                                       
          1.   Unreported Income                                                      
               As a general rule, the Commissioner’s determinations of                
          deficiencies in tax set forth in a notice of deficiency are                 
          presumed correct, and the taxpayer bears the burden of showing              
          that these determinations are in error.  Rule 142(a); Welch v.              

               2  On Apr. 30, 2004, the Court filed as a petition a letter            
          received from petitioner.  By an order dated May 10, 2004, the              
          Court directed petitioner to file an amended petition complying             
          with the Rules of the Court as to form and content of a proper              
          petition by June 24, 2004.  Despite issuance by the Court of                
          several orders to petitioner in the ensuing months, petitioner              
          did not submit an amended petition to the Court until Apr. 28,              

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