Nathaniel Caleb Avery - Page 11

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          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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