- 12 -
to produce "reasonable and probative information" concerning the
deficiency for each year at issue in addition to the parties'
stipulation in this case about the information returns with
respect to Mr. Hardy that were filed with respondent for each
such year.13 That is because we conclude that petitioner has not
asserted "a reasonable dispute with respect to any item of
income" that was reported to respondent as having been paid to
and/or earned by Mr. Hardy and has not shown that she "fully
cooperated" with respondent.
On the record before us, we find that during 1983, 1984, and
1985 income of $48,264.38, $22,986,14 and $45,004, respectively,
was paid to and/or earned by Mr. Hardy. Although we have found
that during 1985 income of $45,004 was paid to and/or earned by
Mr. Hardy, respondent's determination of the deficiency for 1985
(viz., $2,059) was based upon one-half of only $29,684 of commu-
nity income of Mr. Hardy. Respondent does not claim a deficiency
for 1985 in an amount greater than that determined in the notice.
Accordingly, we conclude that respondent is not claiming that Mr.
13 As stated above, respondent did present evidence, in addition
to the parties' stipulation that certain income was reported to
respondent as having been paid to and/or earned by Mr. Hardy
during the years at issue, to support her contention that Mr.
Hardy has income for those years.
14 Although respondent determined a deficiency for 1984 based on
one-half of Mr. Hardy's community income of $27,608, on brief,
she claims a deficiency for that year based on one-half of Mr.
Hardy's community income of only $22,986.
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