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[*21] petitioner’s case for trial during the Mobile, Alabama, trial session beginning April 25, 2011.

I.

A.

The Commissioner’s deficiency determination ordinarily is entitled to a presumption of correctness. , 324 F.3d 1289, 1293 (11th Cir. 2003), T.C. Memo. 2001-43. However, when a case involves unreported income, the U.S. Court of Appeals for the Eleventh Circuit, to which an appeal in this case would lie absent a stipulation to the contrary, sec. 7482(b)(1)(A), (2), has held that the Commissioner’s determination of unreported income is entitled to a presumption of correctness only if the determination is supported by a minimal evidentiary foundation linking the taxpayer to an income producing activity, , 994 F.2d 1542, 1549 (11th Cir. 1993),  T.C. Memo. 1991-636. Once the Commissioner produces evidence linking the taxpayer to an income-producing activity, the presumption of correctness applies and the burden of production shifts to the taxpayer to rebut that presumption by establishing that the Commissioner’s determination is arbitrary or ___________