- 11 -
would have caused a shift in the burden of going forward with the
evidence.
Section 6201(d) requires petitioner to show that he fully
cooperated with respondent, and to make a reasonable dispute.
Petitioner did not deny that he received the income at issue.
Rather, he stated that he performed no services for and received
no cash from Priester. Even if these statements were true, they
would not disprove receipt of the income in question, such income
being in the form of a discount. Petitioner tacitly admitted to
receiving a discount. This does not constitute a reasonable
dispute. Furthermore, the record contains no evidence other than
petitioner's testimony, which casts doubt on petitioner's
statement on brief that he fully cooperated with respondent. See
Schaeffer v. Commissioner, T.C. Memo. 1994-206. Because
petitioner has failed to show a reasonable dispute as to the
income in question, and has failed to fully cooperate with
respondent, the burden of going forward and producing "reasonable
and probative information" concerning the deficiency beyond the
information return has not shifted to respondent. As to the
ultimate burden of proof, in light of the complete lack of
evidence beyond petitioner's testimony, we conclude that
petitioner also has not met his burden of proving that he failed
to receive the income in question in 1991. See Kluger v.
Commissioner, 91 T.C. 969, 976-977 (1988); Kluger v.
Commissioner, 83 T.C. 309, 310 n.1 (1984); Petersen v.
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