- 7 - Petitioner asserts that respondent has not carried the burden of proving the accuracy of the disputed Forms 1099. Although petitioner argues that neither of the Forms 1099 is valid, at trial, petitioner addressed only the validity of the Form 1099 issued to him by Masterguard. For support, petitioner cites section 6201(d) and claims that he has fully cooperated with respondent by granting access to all records and information for 1988 in his possession. Section 6201(d), amended by section 602, Taxpayer Bill of Rights 2, Pub. L. 104-168, 110 Stat. 1452, 1463 (1996), is effective as of July 30, 1996. The petition was filed on June 24, 1996, and the trial in this case was held on February 5, 1997. We will assume arguendo that section 6201(d), as amended, is applicable in this case. Section 6201(d) provides that if the taxpayer, in a court proceeding, asserts a reasonable dispute with respect to the income reported on an information return, and fully cooperates with the Commissioner, then the Commissioner shall have the burden of producing reasonable and probative information in addition to the information return.2 See Dennis 2 Sec. 6201(d) provides: SEC. 6201(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 (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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