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were the cause of a dispute between petitioner and the credit
union. Petitioner asserted that the interest income from the
credit union had been incorrectly reported to the IRS because the
credit union had a vendetta against him.
Petitioner has asserted a reasonable dispute with respect to
the interest income, and the information produced by respondent
does not show any more than $0.18 being deposited into
petitioner’s savings account. Therefore, respondent has not met
the burden imposed by section 6201(d).
Respondent contends that the insurance distribution was the
result of a loan that petitioner took out from an annuity policy.
Petitioner denies that he had an annuity policy with Farmers.
Respondent produced no probative information about the nature of
the payment. Therefore, respondent has not met the burden
imposed by section 6201(d). These issues are decided in favor of
petitioner.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011