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information concerning that deficiency in addition to such
information return. Sec. 6201(d).
Petitioner did not introduce any evidence to refute
respondent’s evidence or show that respondent’s determination of
petitioner’s income is in error. We conclude that respondent
does not have the burden of production under section 6201(d)
because petitioner did not assert a reasonable dispute with
respect to any item of income reported on an information return
and petitioner has not fully cooperated with respondent. Even if
respondent had the burden of proceeding under section 6201(d),
respondent met that burden by producing information returns with
certified transcripts from respondent’s administrative files and
from Social Security Administration files and declarations and
supporting records from Douglas Goodall and Donna Bolio. The
declarations were made under penalties of perjury pursuant to and
are in the form required by 28 U.S.C. section 1746 (2000).
The declarations are admissible under rules 803(6) and
902(11) of the Federal Rules of Evidence. Rule 803(6) of the
Federal Rules of Evidence provides an exception to the hearsay
rule for records that are kept in the course of a regularly
conducted activity and made at or near the time of the event by a
person with knowledge. Rule 902(11) of the Federal Rules of
Evidence states the requirements for self-authentication of a
business record. To qualify under rule 902(11), a domestic
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