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GUTIERREZ v. COMMISSIONER

Docket No. 11393-02.

86 T.C.M. 611 (2003)

T.C. Memo. 2003-321

Rafael M. Gutierrez and Rosario Gutierrez v. Commissioner.

United States Tax Court.

Filed November 20, 2003.

Attorney(s) appearing for the Case

Jeffrey D. Moffatt, for the petitioners.

Jean Song, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge.

Petitioners petitioned the Court to redetermine a $43,812 deficiency in their 1998 Federal income tax and an accuracy-related penalty of $8,762.40 under section 6662(a).1 After concessions, we decide the following issues:

1. Whether the burden of proof has been shifted to respondent by virtue of section 7491(a). We hold that the burden of proof remains with petitioners...

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