-11-
computer-generated IRS forms in a deficiency determination); see
also Parker v. Commissioner, 117 F.3d 785 (5th Cir. 1997)
(holding that it is not arbitrary for the Commissioner to rely
upon third-party payor reports in a case of unreported income
where the taxpayer does not file a return or other sworn document
disputing the income reflected in those reports). Petitioner
presented no evidence to suggest that this form was inaccurate.
See Hardy v. Commissioner, supra at 1004 (shifting to the
taxpayer the burden of showing the unreported income
determination was not erroneous after the Commissioner presented
substantive evidence of unreported income); see also Green v.
Commissioner, T.C. Memo. 1996-107, affd. without published
opinion 113 F.3d 1251 (11th Cir. 1997). Respondent also
introduced, and we admitted, into evidence records of Efeckta
which support respondent’s determination. The records show that
during 2002 Efeckta paid to petitioner a semimonthly salary of
$6,000. The records are consistent with respondent’s claim of
unreported income, and we hold that respondent has sufficiently
linked petitioner with the unreported income. See Hardy v.
Commissioner, supra at 1005. Given petitioner’s failure to
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