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for the destruction of a boat and accompanying personal property;
(5) whether petitioner is liable for additions to tax pursuant to
section 6651(a)(1) for failing to file timely Federal income tax
returns for the years at issue; and (6) whether petitioner is
liable for additions to tax pursuant to section 6654 for failing
to pay estimated taxes.
The stipulations and exhibits are incorporated herein by
this reference. For convenience, we shall set forth only the
facts necessary to clarify the ensuing discussion.
Prior to trial in Hadsell v. Commissioner, T.C. Memo. 1994-
198 (Hadsell I), petitioner served subpoenas duces tecum by mail
upon Detective Mike Menzies (Detective Menzies), an employee of
the Newport Police Department, Zong Yan Yu,2 petitioner’s wife,
and Lai Fong Lee, Zong Yan Yu’s aunt and petitioner’s former
employer. Petitioner served the three subpoenas without
tendering mileage and witness fees as required by Rules 147 and
148. None of the witnesses appeared at trial on October 14,
1993, and the Court refused to enforce the subpoenas because
petitioner failed to tender the required mileage and witness
fees.
2 Zong Yan Yu was referred to as “Zong Gan Yu Hadsell” in
Hadsell v. Commissioner, T.C. Memo. 1994-198, and in Hadsell v.
Commissioner, 107 F.3d 750 (9th Cir. 1997).
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