Opinion
3544-21
04-11-2022
JEREMY EDWIN PORTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Travis A. Greaves, Judge
Pursuant to the determination of the Court, as set forth in its Memorandum Findings of Fact and Opinion, T.C. Memo. 2022-25, filed March 28, 2022, it is
ORDERED that petitioner's oral motion to shift burden of proof, made on January 24, 2022, is denied. It is further
ORDERED AND DECIDED that the determination set forth in the Final Determination letter, dated September 15, 2020, a copy of which is attached to the petition, is sustained.