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The business records and checks respondent introduced
establish that petitioner received income from medical and
healthcare payments during 2001. While this evidence covers only
16 of the 25 third-party payors from which respondent determined
petitioner received income, it establishes a minimal factual
predicate or foundation of substantive evidence linking the
taxpayer to income-generating activity. We conclude that
respondent laid the requisite foundation for the contested
unreported income from medical and healthcare payments and that
petitioner bears the burden of proving respondent’s determination
incorrect.
Respondent did not, however, introduce any evidence
establishing that petitioner received interest income during
2001. Because respondent has not laid the requisite foundation
in this regard, we find that the alleged interest income of $72
is not included in petitioner’s gross income for 2001.
Petitioner did not attend the trial, and he did not attempt
through his counsel to introduce any evidence regarding the items
of unreported income. Therefore, we conclude that petitioner has
failed to carry his burden of proof. Respondent’s unreported
6(...continued)
Therefore, the records and checks were properly admitted into
evidence at trial, and we do not consider petitioner’s arguments
further.
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