-8- Exhibit No. Obligor Obligee Amount 12-P In Touch Beverly Stool $80,000 13-P In Touch Jeff Giddings 60,000 14-P In Touch Gene Longcrier 48,000 15-P In Touch Curzon, Cumbey 33,615 16-P In Touch Eugene de Verges 15,000 18-P Lloyd Gilbert In Touch 30,000 19-P James Coates In Touch 25,000 Although we initially deferred ruling on the admissibility of the promissory notes, respondent’s counsel withdrew his objection to Exhibits 12-P, 13-P, and 14-P after he introduced the original promissory notes as Exhibits 22-R, 21-R, and 20-R, respectively. In his posttrial brief, respondent conceded that, under Federal Rule of Evidence 901(a), petitioner properly authenticated the remaining promissory notes containing the signatures of James Coates and Lloyd Gilbert. Consequently, we admit Exhibits 15-P, 16-P, 18-P, and 19-P. Petitioner introduced three of the promissory notes, Exhibits 12-P, 13-P, and 14-P, to substantiate the consulting fees deducted and amortized as startup costs on In Touch’s 2000 return and in support of his contention that the fees in question were properly accrued in 2000. However, petitioner never delivered the promissory notes to the consultants and did not introduce any evidence to describe the dates, nature, and amounts of the services allegedly provided by the three consultants who were the obligees of the notes.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007