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proceeding, asserts a reasonable dispute with respect to income
reported on an information return and fully cooperates with the
Commissioner, the Commissioner has the burden of producing
reasonable and probative information in addition to the
information return. Hardy v. Commissioner, T.C. Memo. 1997-97,
affd. 181 F.3d 1002 (9th Cir. 1999). The Court is satisfied that
the requirements of section 6201(d) have been met, and the burden
of going forward is on respondent with respect to this additional
income.
The Court concludes that respondent has met the burden of
producing reasonable and probative information with respect to
the deficiency. In the audit of petitioners’ return,
respondent’s revenue agent, Elizabeth Isgett, obtained from ARL a
summary of the checks issued to Mr. Hall in 2000 (check summary).
The check summary was a complete record of ARL’s payments and
deductions with respect to Mr. Hall for the year at issue. It
contained a column labeled “1099 Amount”. Ms. Isgett determined
that the income and expense items on the check summary, when
combined, produced the net figure of $95,455 reported to the
Internal Revenue Service by ARL.4 This information was
4 Ms. Isgett compared the check summary with the
available weekly settlement statements and determined that the
“1099 YTD” total on the Dec. 21 settlement statement ($43,984.72)
did not represent the net effect of Mr. Hall’s income and
expenses as reflected in his check summaries. In fact, this
“1099 YTD” total did not correspond to any of the records she
(continued...)
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