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subsequently recalendared for trial at Washington, D.C.,
commencing on September 19, 2000.
In subsequent meetings and negotiations with respondent,
petitioner did not produce all of his records to respondent, and
the records that were produced were tendered in an unorganized
fashion. As a result, on June 12, 2000, respondent commenced
formal discovery in the form of requests for admissions.
On July 6, 2000, Frank A. Thomas III (Mr. Thomas), entered
an appearance as counsel for petitioner. Pursuant to
petitioner’s motion for continuance, a further continuance was
granted, and this case was continued for trial on October 25,
2000. On July 21, 2000, petitioner filed a status report with
the Court alleging compliance with the Court’s order to produce
his records. The items provided to respondent allegedly included
summaries of petitioner’s bank accounts, purchases shown in
connection with Schedule C, Profit or Loss From Business,
inventories, work sheets used in preparation of petitioner’s tax
returns, summaries of petitioner’s Schedule E, Supplemental
Income and Loss, activities by items of expense, depreciation
schedules, other records pertaining to petitioner’s expenses, and
photocopies of petitioner’s ledgers for the Schedule C expenses.
Respondent’s status report sets forth a different version of
petitioner’s level of cooperation. Respondent stated that
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