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raises. With respect to the admissibility into evidence of the
IRS transcripts, as noted above, those transcripts were part of a
joint exhibit that the parties attached to, and incorporated
into, the stipulation of facts that they offered into evidence at
the beginning of the trial. At that time, the Court admitted
into evidence and made part of the record in this case that
stipulation of facts together with the exhibits attached thereto.
Although petitioner failed to preserve in the stipulation of
facts any objection to the IRS transcripts, she objected at trial
to the admissibility into evidence of those transcripts because
“they appear that they are a form of the individual master file
and * * * those aren’t admissible * * * because it’s not read-
able.” The Court overruled petitioner’s objection at trial. On
brief, petitioner renews her objection.
Petitioner contends on brief that the IRS transcripts are
“not admissible as a matter of law.” That is because, according
to petitioner, those transcripts are “indecipherable” and “To be
considered at all, it [sic] can only be considered when admitted
with the 6209 Manual.” In support of her contention that the IRS
transcripts are inadmissible “as a matter of law”, petitioner
relies on Huff v. United States, 10 F.3d 1440 (9th Cir. 1993),
and United States v. Buford, 889 F.2d 1406 (5th Cir. 1989). We
find those cases to be distinguishable from the instant case and
petitioner’s reliance on them to be misplaced. Neither Huff nor
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Last modified: May 25, 2011