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petitioner’s ministerial activities. Petitioners provided the
car insurance policy statement, Colorado vehicle registration/tax
ownership receipt, and car payment history to substantiate their
deduction for the payment of personal property taxes.
OPINION
The burden of proof is on petitioners to show that
respondent’s determinations set forth in the notice of deficiency
are incorrect. Rule 142(a)(1); Welch v. Helvering, 290 U.S. 111,
115 (1933). In certain circumstances, if the taxpayer introduces
credible evidence with respect to any factual issue relevant to
ascertaining the taxpayer’s proper tax liability, section
7491(a)(1) places the burden of proof on the Commissioner. Sec.
7491(a)(1); Rule 142(a)(2). For the burden to shift to the
Commissioner, the taxpayer must comply with the substantiation
and recordkeeping requirements of the Internal Revenue Code
(Code). Sec. 7491(a)(2)(A) and (B). In addition, section
7491(a)(2) requires that the taxpayer cooperate with reasonable
requests by the Commissioner for “witnesses, information,
documents, meetings, and interviews”. Sec. 7491(a)(2)(B). We
conclude that the burden of proof has not shifted to respondent
with respect to any of the issues in this case. To this end, we
find that petitioners failed to cooperate with respondent during
the audit of their 2000 and 2001 Federal income tax returns. We
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