-5-
or erroneous. Hardy v. Commissioner, 181 F.3d 1002, 1004 (9th
Cir. 1999), affg. T.C. Memo. 1997-97.
We conclude that respondent has met his burden of production
as to the unreported income determined in the notice of
deficiency. Respondent introduced, and we admitted, into
evidence respondent’s worksheets listing the amounts of income
that third parties represented to respondent as having been paid
to petitioner, and petitioner has not challenged the accuracy of
these worksheets. See Green v. Commissioner, T.C. Memo. 1996-
107, affd. without published opinion 113 F.3d 1251 (11th Cir.
1997). In addition, petitioner stipulated having received $327
in interest income and $25,685 in wages. Respondent also
introduced, and we admitted, into evidence the declarations of
records of the regularly conducted activity of Hy-Vee Inc.,
Carson Services Inc., Perkins Family Restaurants, K-Mart Corp.,
and Hoff Mechanical Inc., and business records affidavits from
Edward Jones, all of which support the determination made by
respondent. We hold that respondent has sufficiently linked
petitioner to the unreported income. See Hardy v. Commissioner,
supra at 1004. Given petitioner’s failure to disprove
respondent’s determination of unreported income, as modified
through concessions, we sustain the determination as modified.
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