Charles A. Dennis and Alison M. Dennis - Page 11

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          would have caused a shift in the burden of going forward with the           
               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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