Alan D. Stang - Page 10

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               Counsel for respondent then sought to enter additional                 
          corroborative evidence in support of respondent’s position.                 
          Respondent first offered the declaration of Missy Wittman, the              
          human resources and payroll manager for GCE, with attached                  
          documents relating to petitioner’s employment and pay, under                
          rules 803(6) and 902(11) of the Federal Rules of Evidence.                  
          Respondent indicated that the materials had been provided to                
          petitioner prior to trial, and petitioner corroborated that he              
          had been given the documents “two weeks ago”.  Petitioner,                  
          however, objected to their admission, complaining that the timing           
          had not permitted him a fair opportunity to challenge the                   
          materials and that various documents constituted hearsay, were              
          incomplete, and were secondary evidence.  The Court overruled the           
          objection and admitted the exhibit.                                         
               Respondent next sought to enter under rule 902(1) of the               
          Federal Rules of Evidence a Certificate of Official Record,                 
          Information Returns Processing File (IRP) On-Line Transcript, for           
          petitioner’s taxable years 1999, 2000, and 2001.  The document              
          was an original signed and under seal.  Petitioner objected that            
          the document was created from hearsay, but the Court again                  
          overruled the objection.                                                    
               Respondent then called to the stand Wayne Johnson, a revenue           
          agent, who testified with regard to maintenance of computer                 
          records and transcripts within the IRS.  On the basis of this               






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