John Wadsworth - Page 4

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                    Upon the receipt of the above information and                     
               documents, and a meeting is scheduled, please be                       
               advised that we will tape record the meeting and be                    
               bringing two witnesses to it.                                          
               After receiving Mr. Kotmair's letter dated April 18, 1994,             
          respondent did not further attempt to contact petitioner before             
          issuing her statutory notice of deficiency.                                 
               In her notice of deficiency, respondent determined                     
          petitioner's income for the years in issue based upon data                  
          derived from the Bureau of Labor Statistics (BLS) and                       
          respondent's Information Returns Master File (IRMF).                        
               By notice dated July 31, 1996, this case was set for trial             
          at the trial session of the Court at San Francisco, California,             
          beginning on October 21, 1996.                                              
               On October 8, 1996, respondent served upon petitioner a                
          subpoena duces tecum, requiring petitioner to produce certain               
          documents on October 21, 1996, at the call of the calendar of the           
          trial session of the Court in San Francisco.  The subpoena duces            
          tecum stated:                                                               
                    The Petition filed in John Wadsworth v.                           
               Commissioner, Docket No. 3259-96, states that you, John                
               Wadsworth, did not have any taxable income during the                  
               years 1989 through 1992.                                               
               1.  Please bring any and all documents that evidence                   
               receipt of nontaxable income (such as amounts derived                  
               from loans, gifts, bequests, inheritances, etc.) by you                
               during the years 1989 through 1992.                                    
               2.  Please bring any and all documents that show the                   
               identity of the person who owns the property located at                
               2600 Valley Meadow Court, Oakview, California 93022 at                 
               which you reside (if you are leasing the property,                     




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