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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.
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