- 5 - Section 6201(d) provides that if a taxpayer, in a court proceeding, asserts a reasonable dispute with respect to income reported on an information return and has fully cooperated with respondent, then the burden of producing reasonable and probative information relating to the alleged income may shift to respondent. See Hardy v. Commissioner, 181 F.3d 1002 (9th Cir. 1999), affg. T.C. Memo. 1997-97; Dennis v. Commissioner, T.C. Memo. 1997-275. Section 6201(d) provides as follows: 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 under subpart B or C of part III of subchapter A of chapter 61 by a third party and the taxpayer has fully cooperated with the Secretary (including 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), the Secretary shall have the burden of producing reasonable and probative information concerning such deficiency in addition to such information return. The evidence indicates that petitioner has not satisfied the cooperation requirement of section 6201(d). Petitioner failed to file his Federal income tax returns for the years in issue. Petitioner produced minimal records for respondent’s representatives. Petitioner is not entitled to the benefits of section 6201(d).Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011