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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).
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Last modified: May 25, 2011