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[*25] profit only once. , 66 T.C. at 102;, T.C. Memo. 2010-175, slip op. at 20-21. We therefore reject petitioner’s arguments, and we conclude that respondent’s determinations are entitled to the presumption of correctness.

B.

Generally, the taxpayer bears the burden of proving that the Commissioner’s determinations in a notice of deficiency are erroneous. Rule 142(a);, 290 U.S. 111, 115 (1933). If, however, a taxpayer produces credible evidence with respect to any factual issue relevant to ascertaining the taxpayer’s tax liability and satisfies the requirements of section 7491(a)(2), the burden of proof on any such issue shifts to the Commissioner. Sec. 7491(a)(1). Section 7491(a)(2) requires a taxpayer to demonstrate that he or she complied with the substantiation requirements, maintained all records required under the Code, and cooperated with reasonable requests by the Secretary for witnesses, information, ___________