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him appeared, and no request to secure his appearance by writ of
habeas corpus or otherwise had been made. The parties had not
entered into a stipulation, although they had exchanged
correspondence concerning a stipulation. Respondent introduced
into evidence various documents, including copies of the
indictment and judgment in the criminal case, of petitioner’s tax
returns for 1990 and 1991, and of checks payable to petitioner.
Respondent also called as a witness a special agent of the
Internal Revenue Service (IRS) who had attended petitioner’s
criminal trial. The special agent recounted aspects of the
testimony given at the criminal trial, particularly that of
alleged coconspirator Hatcher, and explained how respondent had
calculated the unreported income at issue in the present
proceeding.
Upon the conclusion of the proceedings, the Court issued an
order directing petitioner to show cause why the case should not
be decided on the record made at trial.
Petitioner filed a response to the order to show cause and a
motion to reopen the record. These papers, and items attached
thereto, generally attacked the testimony given at the criminal
trial, quarreled with respondent’s computation of the unreported
income, and asserted petitioner’s indigence and inability to pay
the amounts sought by the IRS. The response to the order to show
cause also included the following statement:
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