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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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