§602

d to carry her burden of proving that respondent’s determination that she received $120,200 of nonemployee compensation in 1988 was erroneous, and we sustain it.5 5 Although sec. 6201(d), as amended by the Taxpayer Bill of Rights 2, Pub. L. 104-168, sec. 602(a), 110 Stat. 1463 (1996), imposes certain additional evidentiary burdens on the Commissioner where a taxpayer asserts a “reasonable dispute” with respect to an item of income reported on an information return by a third party and the taxpay

602(b), 89 Stat. at 58. There is no evidence that Congress has ever regarded these rules as unreasonable or contrary to its purpose in enacting subpart F.

602(b), 89 Stat. at 58. There is no evidence that Congress has ever regarded these rules as unreasonable or contrary to its purpose in enacting subpart F.

° The purchase agreements had boilerplate clauses stating that the shares weren't registered, that Scott and Debra received them only under the accredited- investor exemption, see Small Business Investment Incentive Act of 1980, Pub. L. No. 96-477, sec. 602, 94 Stat. at 2294 (codified as amended at 15 U.S.C. sec. 77d(a)(5) (2016)); see generally Wright v. Nat'l Warranty Co., 953 F.2d 256, 259- 60 (6th Cir. 1992), and that they cannot sell them unless the shares got registered or an exception to

° The purchase agreements had boilerplate clauses stating that the shares weren't registered, that Scott and Debra received them only under the accredited- investor exemption, see Small Business Investment Incentive Act of 1980, Pub. L. No. 96-477, sec. 602, 94 Stat. at 2294 (codified as amended at 15 U.S.C. sec. 77d(a)(5) (2016)); see generally Wright v. Nat'l Warranty Co., 953 F.2d 256, 259- 60 (6th Cir. 1992), and that they cannot sell them unless the shares got registered or an exception to

CUSTODY OF * * * [LR]: The custody of minor child * * * [LR] is at issue in this cause The Court considered the criteria set forth in Section 602 of the Illinois Marriage and Dissolution of Marriage Act.

CUSTODY OF * * * [LR]: The custody of minor child * * * [LR] is at issue in this cause The Court considered the criteria set forth in Section 602 of the Illinois Marriage and Dissolution of Marriage Act.

rden of proving that the value of the prize was less than the amount determined by respondent.15 See Rule 142(a); Commissioner v. 15Although neither party raised the issue, sec. 6201(d), as amended by the Taxpayer Bill of Rights 2, Pub. L. 104-168, sec. 602(a), 110 Stat. 1452, 1463 (1996), became effective on July 30, 1996, and applies to judicial proceedings filed on or after that date. Sec. 6201(d) provides that if the taxpayer in a court proceeding asserts a reasonable dispute with respect to

bout California Barbecue or its operations, income or expenses to respondent or the Court. Thus, while petitioner 4 Although neither party has raised the issue, we note that sec. 6201(d), as amended by the Taxpayer Bill of Rights 2, Pub. L. 104-168, sec. 602(a), 110 Stat. 1452, 1463 (1996), was effective as of July 30, 1996. Sec. 6201(d) provides that if the taxpayer, in a court proceeding, asserts a reasonable dispute with respect to the income reported on an information return, and fully coope

en of proof. Here, however, the evidence sufficiently connects petitioner to the receipt of the income at issue to preclude considerations affecting the burden of proof. Cf. sec. 6201(d), as added by the Taxpayer Bill of Rights 2, Pub. L. 104- 168, sec. 602(a), 110 Stat. 1452, 1463 (1996); Schaffer v. Commissioner, 779 F.2d 849, 857-858 (2d Cir. 1985), affg. in part and remanding in part Mandina v. Commissioner, T.C. Memo. 1982- 34. - 18 - See Commissioner v. Bollinger, 485 U.S. 340, 344 (1988);

Section 6201(d), amended by section 602, Taxpayer Bill of Rights 2, Pub.

ding alone, carries no weight.").8 7 The parties stipulated that during the years in issue petitioner "was married and was legally responsible for one dependant [sic] child." 8 Sec. 6201(d),amended by the Taxpayer Bill of Rights 2, Pub. L. 104-168, sec. 602, 110 Stat. 1452, 1463 (1996), is effective as of July 30, 1996. Sec. 6201(d) provides that if the taxpayer, in a court proceeding, asserts a reasonable dispute with respect to the income reported on an information return, and fully cooperates

therefore urges that respondent has failed to carry the burden of proving the accuracy of the disputed Form 1099. The notice of deficiency in this case is dated September 29, 1995. The petition is dated December 6, 1995. Section 6201(d), amended by sec. 602, Taxpayer Bill of Rights II, Pub. L. 104-168, 110 Stat. 1452, 1463 (1996), is effective as of July 30, 1996. The trial was held on October 21, 1996. Assuming arguendo that section 6201(d) is applicable in this case, it provides that if the ta