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ample notice of respondent's duplication grounds. Mayerson v.
Commissioner, 47 T.C. at 349.
Accordingly, we conclude that the notice of deficiency was
not arbitrary and that the burden of proof with respect to the
disputed issues remained with petitioner.
B. Testimony of Alan Hull
In his answering brief, petitioner contends that the
testimony of respondent's witness, Alan Hull, should be rejected
by the Court. While petitioner did not object to Mr. Hull's
testimony at trial, he argues that Mr. Hull lacked the necessary
foundation to testify because he was not involved in the audit or
the issuance of the deficiency notice. We disagree.
Mr. Hull is a Technical Advisor to the IRS District Counsel.
He has been an IRS employee for 18 years and is a Certified
Public Accountant in Colorado. Mr. Hull, who had reviewed
petitioner's records, the IRS administrative file, and the
stipulation of facts with attached exhibits, was called as
respondent's witness to explain which of petitioner's expenses
were duplicated or otherwise disallowed. He was a qualified,
competent, and thorough witness who gave reliable and detailed
testimony.
Tax Court trials are conducted according to the rules of
evidence applicable in trials without a jury in the United States
District Court for the District of Columbia. Sec. 7453; Rule
143(a). These rules include the Federal Rules of Evidence.
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