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relating to the liability of the taxpayer for a tax imposed under
subtitle A or B of the Code. Additionally, section 6201(d)
provides that if a taxpayer asserts a reasonable dispute with
respect to any item of income reported on an information return
filed with the Secretary by a third party and the taxpayer has
fully cooperated with the Secretary, the Secretary shall have the
burden of producing reasonable and probative information
concerning such deficiency in addition to such information
return.
At trial, petitioner testified and stipulated he received
the wages, pension distribution, interest, and dividend set forth
in the notices of deficiency. Petitioner, however, disputed that
the aforementioned amounts are income. Accordingly, as
petitioner does not dispute the facts, failed to introduce
credible evidence, and has not asserted a reasonable dispute
regarding the items listed on the information returns, sections
6201(d) and 7491(a) are inapplicable. Parker v. Commissioner,
117 F.3d 785, 786 (5th Cir. 1997); Tanner v. Commissioner, 117
T.C. 237, 241 (2001), affd. 65 Fed. Appx. 508 (5th Cir. 2003).
At trial and on brief, petitioner advanced shopworn
arguments regarding why the wages, pension distribution,
interest, and dividend are not income. His arguments are
characteristic of tax-protester rhetoric that has been
universally rejected by this and other courts. See Wilcox v.
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Last modified: May 25, 2011