Charles A. Dennis and Alison M. Dennis - Page 9

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               On brief, petitioner asserts that respondent has not carried           
          the burden of proving the accuracy of the disputed Form 1099.               
          For support, he cites section 6201(d), which provides:                      
                    (d) Required Reasonable Verification of                           
               Information Returns.--In any court proceeding, if a                    
               taxpayer asserts a reasonable dispute with respect to                  
               any item of income reported on an information return                   
               filed with the Secretary * * * by a third party and the                
               taxpayer has fully cooperated with the Secretary                       
               (including providing, within a reasonable period of                    
               time, access to and inspection of all witnesses,                       
               information, and documents within the control of the                   
               taxpayer as reasonably requested by the Secretary), the                
               Secretary shall have the burden of producing reasonable                
               and probative information concerning such deficiency in                
               addition to such information return.                                   
          Petitioner claims that he has fully cooperated with respondent by           
          granting access to all records and information for the tax years            
          in question and therefore urges that respondent has failed to               
          carry the burden of proving the accuracy of the disputed Form               
          1099.                                                                       
               The notice of deficiency in this case is dated September 29,           
          1995.  The petition is dated December 6, 1995.  Section 6201(d),            
          amended by sec. 602, Taxpayer Bill of Rights II, Pub. L. 104-168,           
          110 Stat. 1452, 1463 (1996), is effective as of July 30, 1996.              
          The trial was held on October 21, 1996.  Assuming arguendo that             
          section 6201(d) is applicable in this case, it provides that if             
          the taxpayer, in a court proceeding, asserts a reasonable dispute           
          with respect to income reported on an information return, and               
          fully cooperates with respondent, then respondent shall have the            
          burden of producing reasonable and probative information in                 




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