- 7 - records, each containing hundreds or perhaps thousands of documents on the ground that respondent had refused to stipulate after petitioner had proffered them on May 1, 2002, only 1 day before the trial date. Respondent’s counsel explained that she refused to blindly stipulate four boxes of materials without some explanation or understanding of the individual documents and their relevance and/or relation to the controverted expense or income items. The adjustments for petitioners’ 1992, 1993, and 1994 tax years involved: Underreported gross receipts and disallowed expenses and depreciation on Schedules C (Profit or Loss From Business), income from a distribution from a retirement account for 1993, increase and decrease of reported rental income, disallowance of miscellaneous itemized deductions, self-employment tax, and additions to tax under sections 6651(a)(1) and 6662. The adjustments involved numerous individual items. During the May 2, 2002, hearing, the Court inquired of petitioners as to the organization of the contents of the four boxes. Petitioner Smith, in response, explained that the documents were not necessarily in chronological order and that individual folders did not necessarily relate to any particular adjustment in the notice of deficiency. The Court inspected one of the numerous documents, a folder, and found that it contained a large volume of loose papers and miscellaneous documents.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011