David G. Turner - Page 8

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          v. Commissioner, 832 F.2d 986, 987 (7th Cir. 1987); Newman v.               
          Schiff, 778 F.2d 460, 467 (8th Cir. 1985).                                  
               C.  Respondent’s Determinations Were Correct                           
               Generally, absent application of special statutory                     
          provisions or principles, the Commissioner's determinations in a            
          notice of deficiency are presumptively correct, and the taxpayer            
          has the burden of proving that those determinations are                     
          erroneous.  Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115              
          (1933).  However, section 6201(d) provides that the Secretary               
          shall have the burden of producing, in addition to any                      
          information returns, reasonable and probative information                   
          concerning a deficiency where a taxpayer has asserted a                     
          "reasonable dispute" regarding an item of income reported on a              
          third-party information return and has "fully cooperated" with              
          the Secretary.  See Miner v. Commissioner, T.C. Memo. 2003-39;              
          Gussie v. Commissioner, T.C. Memo. 2001-302.                                
               Respondent conceded at trial certain amounts determined in             
          the notice of deficiency he had issued to petitioner.  Petitioner           
          acknowledged receiving the amounts indicated on the remaining               
          third-party information returns but argued that the payments did            
          not constitute income.  We find that petitioner’s argument does             
          not raise a reasonable dispute with respect to the items of                 
          income reported in the information returns.  See Parker v.                  
          Commissioner, 117 F.3d 785, 787 (5th Cir. 1997) (noting that the            






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