Letter from Registered Agent That Stated 1099 Had Been Issued to Taxpayer and Dividends Paid Not Found Sufficient for IRS to Carry Burden Under §6201(d)

The IRS computers regularly issue CP2000 notices to taxpayers based on Forms 1099 that the IRS receives which show income not reported on the taxpayer’s return.  Such matching programs allow the IRS to obtain taxes in what is, for the agency, a relatively “painless” and “low friction” process where they start with the numbers on the Form 1099 and presume that income is taxable to the taxpayer.

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