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Under section 6201(d), if the taxpayer asserts a “reasonable
dispute” with respect to any item of income reported on a third-
party information return and the taxpayer has “fully cooperated”
with the Secretary, the Secretary shall have the burden of
producing reasonable and probative information concerning a
deficiency in addition to the information return. See Gussie v.
Commissioner, T.C. Memo. 2001-302. Petitioner makes general and
unsubstantiated assertions that the information returns involved
in this case are fraudulent. However, she does not claim to have
made known her dispute to the third parties who prepared them.
She has not “fully cooperated” with the Secretary in providing
information relating to her 1995, 1996, and 1997 tax years. We
conclude that section 6201(d) is not applicable.
Absent application of those special statutory provisions,
the Commissioner’s determinations in a notice of deficiency
generally are presumptively correct, and the taxpayer has the
burden of proving that those determinations are erroneous or
arbitrary. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115
(1933); Kearns v. Commissioner, 979 F.2d 1176, 1178 (6th Cir.
1992), affg. T.C. Memo. 1991-320. However, the Commissioner
cannot rest on the presumption of correctness alone where the
taxpayer challenges the determinations of unreported income made
in the notice of deficiency. United States v. Walton, 909 F.2d
915, 919 (6th Cir. 1990); Dellacroce v. Commissioner, 83 T.C.
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