- 175 -
the testimony of other witnesses.77 The Court further directed
that any witness testifying at the evidentiary hearing would be
precluded from discussing his or her testimony with any other
witness or providing any other witness with a transcript of his
testimony.
II. The Evidentiary Hearing
The evidentiary hearing in these cases was conducted in
Los Angeles on May 13 to 30, 1996, June 10 to 26, 1996, and
August 18, 1997. The Court heard testimony from 29 witnesses
during the evidentiary hearing and received approximately 500
exhibits. The transcripts of the proceedings consist of more
than 6,700 pages. In addition, between May 13, 1996, and
October 6, 1997, the parties filed with the Court a stipulation
of facts and first through sixth supplemental stipulations of
facts.
77 Rule 145(a) is designed to prevent witnesses from
tailoring their testimony to that of prior witnesses and to
minimize altered testimony. See Thompson v. Commissioner, 92
T.C. 486, 494 (1989).
Page: Previous 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 NextLast modified: May 25, 2011