Clyde E. Owens and Marie W. Owens - Page 14

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          quarterly Federal excise tax returns for September 30 and                   
          December 31, 1981; and various documents concerning a levy in               
          January 1996.  At the time of trial, petitioners had not                    
          identified or exchanged any other documents they would offer into           
          evidence at trial.                                                          
               2.   Trial                                                             
               At trial, Mr. Owens continued to criticize respondent's                
          agents.  He leveled several personal insults against respondent's           
          agent McEver.                                                               
               Petitioners refused several requests from the Court that               
          they address issues raised by the notices of deficiency.  The               
          Court advised petitioners that the notices of deficiency are                
          presumed to be correct and that they should try to meet their               
          burden of proving that they are not correct.  Mr. Owens said that           
          he understood the Court's instructions.                                     
               Petitioners contended that respondent violated their rights            
          under the 1st, 4th, 5th, 7th, 8th, and 14th Amendments to the               
          U.S. Constitution and various Civil Rights Acts.  Mr. Owens said            
          that each petitioner should receive $100,000 in damages.                    
               Petitioners sought to introduce into evidence a large                  
          quantity of documents that petitioners had not exchanged,                   
          identified in writing, or stipulated as required by the Court's             
          orders described above.  Respondent's counsel did not object to             
          the admission of documents if Poole had seen them at her meeting            
          with Mrs. Owens and Ms. Feltrinelli.  Petitioners could not                 

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