Christopher Richardson - Page 4

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          required him to waive his Fifth Amendment privilege against                 
          self-incrimination.  Petitioner did not identify or exchange any            
          documents, identify witnesses, or file a pretrial memorandum as             
          required by the Standing Pretrial Order.  Respondent complied               
          with these requirements.                                                    
                                       OPINION                                        
          A.   Burdens of Production and Proof                                        
               1.   Burden of Production                                              
                    a.   Section 6201(d)                                              
               If a taxpayer asserts a reasonable dispute with respect to             
          any item of income reported on a third-party information return             
          and the taxpayer has fully cooperated with the Secretary, the               
          Secretary has the burden of producing reasonable and probative              
          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            






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