-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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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