- 6 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011