Gloria J. Spurlock - Page 1

                                 T.C. Memo. 2003-124                                  

                               UNITED STATES TAX COURT                                

                          GLORIA J. SPURLOCK, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 6438-01.              Filed April 29, 2003.                 

                    P did not file Federal income tax returns for                     
               1995, 1996, and 1997.  R issued a notice of deficiency                 
               in which he determined that P received wages,                          
               nonemployee compensation, and distributions from                       
               individual retirement plans for each of the years.  R                  
               based his determinations on third-party information                    
                    Held:  Various third-party records that R offered                 
               in support of his determinations are admissible                        
               evidence under rules 803(6) and 902(11) of the Federal                 
               Rules of Evidence, which allow the introduction of                     
               records of a regularly conducted activity if, inter                    
               alia, the records are accompanied by a written                         
               declaration of their custodian or other qualified                      
                    Held, further, R’s determinations of unreported                   
               income are sustained.                                                  

Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011