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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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