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additional evidence concerning petitioners' liability for
the additions to tax that were determined by respondent.
In connection with that further trial, petitioners
submitted to the Court and served on respondent the
"expert" witness reports of Mr. Paul M. Raynault, founder
and chairman of Computer Leasing, Inc., a firm specializing
in computer lease financing and management, and Professor
George Mundstock, a professor of law at the University of
Miami. In response, respondent filed a motion in limine
asking the Court to exclude that "expert" testimony on
the ground that it is neither relevant nor helpful to
the trier of fact. At the further trial, the Court took
respondent's motion in limine under advisement and
permitted both experts to testify subject thereto.
Petitioners presented no other testimony or evidence.
FINDINGS OF FACT
The facts are set forth in Robertson I and are
incorporated herein by reference. We restate only those
facts necessary to address petitioners' position that "the
Court should vacate those portions of its decision [sic]
relating to additions to tax and hold that Petitioner is
not liable for any such additions pursuant to Sections
6653(a) and 6661."
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