-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.
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