Stephanie K. Mills - Page 5

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          business deductions" (emphasis added) for 2001, which constitutes           
          an admission that she was engaged in income-producing activities            
          for that year.  In light of petitioner's admission and her                  
          failure to deny receipt of the alleged income in 2001, it is                
          doubtful respondent has an evidentiary burden.  See Parker v.               
          Commissioner, 117 F.3d 785, 786-787 (5th Cir. 1997); White v.               
          Commissioner, T.C. Memo. 1997-459.                                          
               Even if respondent had a burden, he has adduced evidence               
          linking petitioner to the income alleged in the notice.  Mr.                
          Meadows's uncontradicted testimony was that petitioner provided             
          real estate sales services to Royal Floridian by Spinnaker, LLC,            
          during 2001 in connection with the marketing of time-shares, and            
          was compensated by Royal Floridian on a commission basis (in the            
          amount determined in the notice).  We are likewise satisfied that           
          a minimal evidentiary foundation has been laid with respect to              
          the alleged income from Accumen Realty Inc., since respondent's             
          evidence links petitioner to income-producing activity as a real            
          estate agent in 2001.  We accordingly reject petitioner's                   
          challenge to the notice of deficiency.                                      
          Respondent's Motion To Dismiss                                              
               The Court may dismiss a case at any time and enter a                   
          decision against the taxpayer for failure properly to prosecute             
          her case, failure to comply with the Rules of this Court or any             
          order of the Court, or for any cause which the Court deems                  

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