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are secondary evidence, and that respondent has no personal
knowledge as to the validity of the documents. The documents
were received into evidence over the objection of petitioner.
We find that the evidence provided by respondent was
reliable in that it met the hearsay and authentication exceptions
in rules 803(6) and 902(11) of the Federal Rules of Evidence.
All of the underlying documents were kept in the regular course
of business, and the declarations of the validity of these
documents were made by people familiar with their use.
Petitioner did not introduce any evidence to refute the validity
of the evidence. In addition, petitioner has again failed to
provide any evidence that the income determined by respondent is
in error or that he is entitled to file a return claiming marital
status or any deductions. The failure of petitioner to present
any evidence leaves the Court no basis for making any findings
that support petitioner’s assertions.
Petitioner also argued that he was prejudiced by the
documents offered by respondent due to the lack of a fair
opportunity to inspect the documents. Petitioner’s claim is
without merit. First, some of the documents had petitioner’s
signature on them, indicating he was familiar with the evidence
presented. Second, the documents offered at trial were
related to petitioner’s wage income. We find it extremely
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