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Petitioners’ Position During Informal Discovery with
Respect to the Automobile Depreciation Deductions at Issue
In Part V, Section A of Form 4562 attached to petitioners’
1995 joint return, petitioners indicated that they had written
evidence to support the claimed business use during that year of
petitioners’ two automobiles. However, in a letter to respondent
dated July 11, 2000, that petitioners wrote during the course of
the parties’ informal discovery in this case, petitioners indi-
cated that they did not have any mileage logs or other documenta-
tion with respect to the business use during 1995 of those two
automobiles. In another letter to respondent dated July 17,
2000, petitioners indicated that such documentation did not
exist.
Petitioners’ Trial Memorandum
On September 12, 2000, petitioners submitted their trial
memorandum (petitioners’ trial memorandum) to the Court. In
petitioners’ trial memorandum, petitioners advanced, inter alia,
various arguments and contentions challenging the jurisdiction
and authority of the Court. On September 19, 2000, we issued an
Order (September 19, 2000 Order) in which we directed that
petitioners’ trial memorandum be filed as of September 12, 2000,
the date of its receipt by the Court. In that Order, we also
stated that we found the arguments and contentions with respect
to the jurisdiction and authority of the Court that petitioners
advanced in petitioners’ trial memorandum to be frivolous and/or
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