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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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