Scar v. CIR, 814 F.2d 1363

Portillo v. CIR, 932 F.2d 1128

Senter v. CIR, T.C. Memo 1995-311

Weimerskirch v. CIR, 596 F.2d 358 the IRS bears the burden of proving Petitioner had the stated income. “Presumption of correctness of government's tax deficiency assessment does not apply when government's assessment falls within narrow but important category of naked assessment without any foundation; court need not give effect to presumption of correctness in case involving unreported income if tax commissioner cannot present some predicate evidence supporting its determination...”

Portillo v. CIR, 932 F.2d 1129 (5th CIR. 1991). “The need for tax collection does not serve to excuse the government, however, from providing some factual foundation for its assessments.”