Clyde E. Owens and Marie W. Owens - Page 19

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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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