Kim Anthony Polonczyk - Page 7

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          were the cause of a dispute between petitioner and the credit               
          union.  Petitioner asserted that the interest income from the               
          credit union had been incorrectly reported to the IRS because the           
          credit union had a vendetta against him.                                    
               Petitioner has asserted a reasonable dispute with respect to           
          the interest income, and the information produced by respondent             
          does not show any more than $0.18 being deposited into                      
          petitioner’s savings account.  Therefore, respondent has not met            
          the burden imposed by section 6201(d).                                      
               Respondent contends that the insurance distribution was the            
          result of a loan that petitioner took out from an annuity policy.           
          Petitioner denies that he had an annuity policy with Farmers.               
          Respondent produced no probative information about the nature of            
          the payment.  Therefore, respondent has not met the burden                  
          imposed by section 6201(d).  These issues are decided in favor of           
          petitioner.                                                                 
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          













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