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petitioners had less income or more deductions or cost of goods
sold than respondent had allowed as a result of Poole's meetings
with petitioners. The amounts of deductions and cost of goods
that petitioners substantiated in those documents are less than
respondent allowed, and those documents do not show that
petitioners had less income than respondent determined.
Petitioners contend that the Court gave respondent the power
to decide what documents were admissible in evidence. We
disagree. Although not required to do so, respondent did not
object to the admission of certain documents that petitioners had
failed to exchange and identify in writing before trial as
required by several Court orders.
Petitioners contend that the Court allowed respondent to be
late many times but repeatedly denied requests by petitioners.
We disagree. The Court granted two of petitioners' motions to
continue and one of respondent's motions to file a trial
memorandum when respondent substituted counsel in these cases.
At trial, petitioners questioned whether section 7522 has
any bearing on these cases. Section 7522 requires that
respondent describe in a notice of deficiency the basis for and
identify the amounts of tax due, interest, and any additional
amounts, additions to tax, and assessable penalties. Sec.
7522(a) and (b). The notices of deficiency at issue here
complied with section 7522. They include a clear written
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