Alec Jeffrey Megibow - Page 10

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          disallowed the business expenses claimed by petitioner on                   
          Schedules C, with the exception of the amounts shown as fees                
          remitted to NYU.  Additional correspondence sent by Mr. Bentley             
          after that date was reviewed by Ms. O’Connell but was determined            
          not to be pertinent to the adjustments in the statutory notice.             
               The petition in this case was filed on May 9, 2002, and                
          trial was held on May 8, 2003.  Mr. Bentley represented                     
          petitioner.  The stipulated joint exhibits consist of copies of             
          petitioner’s 1997, 1998, and 1999 tax returns; the notice of                
          deficiency; and the March 9, 1998, letter from NYU Medical                  
          Center.  Mr. Bentley introduced into evidence two additional                
          exhibits.                                                                   
               The first is a group of documents purporting to represent              
          production from respondent’s disclosure officer received by                 
          Mr. Bentley in response to one of petitioner’s FOIA requests.               
          The second is a similar group of documents purporting to                    
          represent production from the U.S. Attorney for the Southern                
          District of New York received by Mr. Bentley in response to one             
          of petitioner’s FOIA requests.  As such, the exhibits were                  
          proffered as representing the contents of respondent’s                      
          administrative files with respect to the examination of                     
          petitioner’s 1997 through 1999 returns.  No further explanation             
          was offered by Mr. Bentley.                                                 








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