Douglas L. Hadsell - Page 12




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          refused to reschedule the examination and abruptly ended the                   
          phone call.                                                                    
               In an Order dated May 7, 1998, the Court ordered petitioner               
          to meet with a revenue agent in order to complete the examination              
          of petitioner’s receipts.  Pursuant to that Order, respondent’s                
          agent again attempted to phone petitioner on June 8, 1998, but                 
          petitioner refused to take the call.  Petitioner alleged that the              
          agent had treated him rudely during the previous visit and                     
          demanded that another agent be assigned to the examination.                    
          Petitioner later informed the Court during a conference call on                
          November 6, 1998, that he had destroyed his receipts after                     
          originally meeting with the agent on March 5, 1998.                            
               In light of petitioner’s allegations that he had destroyed                
          his receipts, the Court ordered petitioner to file a status                    
          report with the Court by December 9, 1998, setting forth the                   
          facts surrounding petitioner’s destruction of his tax records.                 
          Petitioner refused to comply with the Order but stated in later                
          filings with the Court that he had destroyed only a portion, not               
          all, of the receipts.  The record in this case was closed on June              
          28, 1999, more than 1 full calendar year after petitioner refused              
          to meet with respondent’s agent.                                               
               The Court has made every attempt to accommodate petitioner                
          in this case; however, the record is clear that petitioner has                 







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