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23, 2006, the Court set petitioner’s case for a date and time
certain of 10:00 a.m. EST on Friday, March 31, 2006.
When petitioner’s case was called for trial on March 31,
2006, petitioner did not appear. Instead, George E. Harp (Mr.
Harp) appeared on petitioner’s behalf, and the Court filed Mr.
Harp’s entry of appearance. Although Mr. Harp offered no
evidence at trial regarding petitioner’s unreported income,3 Mr.
Harp objected to all but one of respondent’s exhibits. After
hearing argument on the objections, we overruled petitioner’s
objections and admitted the exhibits.
OPINION
I. Unreported Income
Section 61(a) defines gross income for purposes of
calculating taxable income as “all income from whatever source
derived”. Respondent determined petitioner received gross income
in the form of taxable interest and medical and healthcare
payments, and that petitioner failed to file a 2001 Federal
income tax return reporting these items.
3 Petitioner did introduce into evidence a letter from
respondent’s counsel outlining documents respondent intended to
use at trial. It is unclear why petitioner introduced this
letter into evidence, as it does not relate to any issue and was
not cited by petitioner on brief.
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