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and dated by the person making service verifying that he or she
had delivered the subpoena to the summoned witness and had
tendered fees and mileage pursuant to Rule 148. The Court
granted respondent’s motions to quash the subpoenas.
At trial on July 15, 2003, petitioner stated that he had 100
boxes of records to support the bases he claimed for equipment
that he sold in the years in issue, but that he did not have them
with him. Trial was continued to give petitioner more time to
present his records to respondent.
3. Trial on January 5, 2004
On July 28, 2003, petitioner faxed to respondent a list
entitled “Fred W. Allnutt, Equipment” that petitioner had not
previously given to respondent.
On November 5, 2003, further trial was set for January 5,
2004, to give petitioner another opportunity to offer evidence
relating to the basis issue. Also on November 5, 2003, the Court
ordered petitioner to provide to respondent, not later than
December 22, 2003, all documents that he wanted to use at trial
to substantiate his claimed bases, organized by asset.
Petitioner failed to provide any additional documents to
respondent by December 22, 2003.
On December 17, 2003, petitioner again prepared subpoenas
for respondent’s revenue agent who audited petitioner’s returns
for the years in issue and his supervisor. Respondent’s
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