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Petitioners have not been denied their due process rights.
They had several opportunities to verify the amounts reported on
their returns both before and during this litigation.
Petitioners did not produce records substantiating their disputed
return positions during the examination of their amended returns,
nor did they produce any at the December 9, 2004, meeting or for
trial. Petitioners adamantly insisted that the affidavits were
sufficient to satisfy their obligations to maintain records and
produce them to respondent upon request. Although petitioners’
position was misguided and ill-advised, they had opportunities
during the examination and during trial to be heard at a
meaningful time and in a meaningful manner. Consequently, we
reject petitioners’ due process argument.
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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Last modified: May 25, 2011