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his receipts by tax year, activity, and type of deduction
claimed. Petitioner promised to cooperate with the examination
“100 percent”. The Court then ordered that the record be held
open for 60 days to allow an examination of petitioner’s
receipts.
On March 3, 1998, one of respondent’s revenue agents
contacted petitioner by phone and explained to petitioner how to
organize his receipts in order to facilitate the examination. On
March 5, 1998, the agent visited petitioner and attempted to
examine his receipts for the years at issue.
The agent found that petitioner had failed to organize his
receipts in any manner and was totally unprepared for the
examination. The agent explained to petitioner that he was
acting pursuant to a deadline set by the Court and suggested that
they reschedule the examination so that petitioner could properly
prepare. Petitioner declined to meet with the agent again and
told the agent that he would be unable to organize the receipts
before the expiration of the Tax Court deadline because he was
appealing his criminal conviction and needed all of his time to
work on the appeal.
The agent decided to give petitioner time to reconsider his
decision and scheduled another call with petitioner for March 11,
1998. When the agent phoned on that date, however, petitioner
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