Cliff Connors - Page 10

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          testified, she did not indicate when petitioner left for China or           
          when he was expected to return.  The renewed motion was denied.             
               During trial, Neal raised for the first time the claim that            
          petitioner was entitled to certain deductions, exemptions, and              
          credits.  The only evidence presented at trial was the testimony            
          of Mrs. Connors to say that she was married to petitioner, which            
          was already stipulated, that they had a daughter together, and              
          that petitioner had two sons.  Mrs. Connors testified that $5,000           
          was paid by petitioner on behalf of his two sons and that,                  
          depending on circumstances, petitioner’s sons were with them                
          “once a week”.                                                              
               At the conclusion of the trial petitioner was directed, on             
          the record and by order to show cause, to make an offer of proof            
          that would justify reopening the record as to evidence regarding            
          petitioner’s liability for penalties in the event the disability            
          payments were taxable.  The Court left open the possibility of              
          petitioner’s testimony if he returned from China.  Neal was told            
          “you’re going to have to make a specific statement as to when               
          Mr. Connors will be available in New York or Washington to                  
          testify.  He can give you an affidavit about what he wants to               
          testify about, and Respondent can decide whether they want to               
          cross-examine.”  He was also informed that any affidavits                   
          provided as part of the offer of proof regarding petitioner’s               
          reliance on tax advice from third parties and professionals                 

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