Terry I. and Louise Major - Page 9

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               A.   Form 4340, Certificate of Assessments, Payments and               
                    Other Specified Matters                                           
               Fed. R. Evid. 902 sets forth the rules for self-                       
          authentication of various types of evidence.  The Court has                 
          thoroughly examined the copies of Form 4340 presented by                    
          respondent, and the Forms 4340 meet the requirements under Fed.             
          R. Evid. 902(1) for admissibility.                                          
               B.   Declarations and the Accompanying Forms 1099                      
               Respondent provided third party records, the Forms 1099,               
          accompanying the declarations of Ms. Yows, Ms. Cooper, Ms. Kerns,           
          and Ms. Mills.  Rule 803 of the Federal Rules of Evidence                   
          specifies exceptions to the general rule, Fed. R. Evid. 802,                
          excluding hearsay.  The Court’s examination of the declarations             
          and their respective attached Forms 1099 reveals that such                  
          records were kept in the course of a regularly conducted business           
          activity.  Except for the Dollarhide checks, the exhibits were              
          made available to petitioner at least 14 days before the calendar           
          call and the trial as required by the Court’s pretrial order.               
          The Dollarhide checks were made available to petitioners 4 days             
          before the trial and were also admitted as rebuttal exhibits.               
               The Court is satisfied that each payor is a “business” for             
          purposes of Fed. R. Evid. 803(6) and Fed. R. Evid. 902(11).                 
          Neither Fed. R. Evid. 803(6) nor Fed. R. Evid. 902(11) requires             
          that the custodian of the record have any personal knowledge of             

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