- 8 - v. Commissioner, T.C. Memo. 1997-275; Hardy v. Commissioner, T.C. Memo. 1997-97. The legislative history of section 6201(d) specifically refers to a situation where there is a dispute over income and further states: Fully cooperating with the IRS includes (but is not limited to) the following: bringing the reasonable dispute over the item of income to the attention of the IRS within a reasonable period of time, and 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). [H. Rept. 104-506, at 36 (1996), 1996-3 C.B. 49, 84; emphasis added.] Petitioner contends that the Form 1099 issued to him by Masterguard is invalid because respondent is unable to determine what portion of the amount reported as nonemployee compensation was for override payments made to an independent authorized dealer on purchases made by other independent authorized dealers, and what portion was for merchandise refunds. Petitioner offered no evidence or testimony regarding his argument that the Form 1099 issued to him by Lexington State Bank is invalid. At trial, respondent introduced no evidence in response to petitioner's contention that the Form 1099 from Masterguard was 2(...continued) 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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