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