In which of the following situations does the burden of proof in a tax matter not automatically shift to the IRS?

a. A court proceeding against an individual taxpayer involves a penalty or addition to tax

b. A taxpayer who did not maintain records

c. The IRS uses statistics to reconstruct an individual's income

d. The IRS uses statistics to reconstruct an individual's income and a court proceeding against an individual taxpayer involves a penalty or addition to tax

e. The IRS uses statistics to reconstruct an individual's income, a court proceeding against an individual taxpayer involves a penalty or addition to tax, and a taxpayer who did not maintain records