- 19 - 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 writtenPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011