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corrections counselor on June 17, 1997, pursuant to an Order of
the Court.
At the trial on January 30, 1998, petitioner testified that
the papers delivered by the Newport Police included receipts
which would substantiate his claimed deductions for the years at
issue, but that he did not bring the receipts to trial because he
“didn’t know that that’s what we were going to be dealing with
today”. A recess was called, and petitioner was excused to
retrieve the documents from the prison law library.
Petitioner returned with a voluminous amount of receipts
which he claimed were from the 1988, 1989, and 1990 taxable
years. The receipts, in no particular order, were all thrown
together in a box. Petitioner had made no attempt to organize
the receipts in any manner, even though he conceded that he had
received the receipts “Three or four months, or six months” prior
to the evidentiary hearing.5
The Court requested that respondent assign a revenue agent
to meet with petitioner and ascertain whether petitioner had
receipts which could substantiate additional business deductions
which had not been allowed in Hadsell I. In order to facilitate
such an examination, the Court instructed petitioner to organize
5 In fact, since the documents were part of the records
delivered by the Newport Police Department on June 17, 1997,
petitioner had possession of the records for over 7 months.
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