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further determined that petitioner’s filing status is “married
filing separate return” and that she is entitled to the standard
deduction and a personal exemption deduction for the 2000 taxable
year.5
Discussion
Generally, the burden of proof is on the taxpayer. Rule
142(a)(1). However, if the taxpayer satisfies the limitations
under section 7491(a)(2) and introduces credible evidence with
respect to any factual issue relevant to ascertaining the tax
liability, then the Commissioner bears the burden of proof with
respect to such issue. Sec. 7491(a). Moreover, if a taxpayer
asserts a reasonable dispute with respect to the income reported
on an information return and fully cooperates, then the
Commissioner shall have the burden of producing reasonable and
probative information in addition to such information return.
Sec. 6201(d); Tanner v. Commissioner, 117 T.C. 237 (2001), affd.
65 Fed. Appx. 508 (5th Cir. 2003); McQuatters v. Commissioner,
T.C. Memo. 1998-88. In the present case, petitioner has not
satisfied the requirements of either section 6201(d) or 7491(a).
Unless indicated otherwise, the burden of proof remains on the
petitioner.
5 Petitioner contends that she is entitled to itemized
deductions and dependency exemption deductions for the 2000
taxable year. Petitioner has not offered any evidence to support
her contention, even though, as we indicated earlier, the Court
has permitted her to supplement the record.
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