Norman W. Klootwyk - Page 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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