-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.Page: Previous 1 2 3 4 5 6 7 8 Next
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