Barry L. Morris - Page 4
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the rest of the accounting records that he was relying on and to
provide them to respondent.
Because petitioner’s records were discovered, during trial,
to be fraught with errors, the Court concluded that respondent
was prejudiced by petitioner’s violation of the pretrial order.
The Court therefore sustained respondent’s objection to the
admission of those documents into evidence. However, the record
was held open until July, 9, 2007, to offer petitioner an
opportunity to confer with respondent in order to reach an
agreement concerning the filing of additional documents. Such
documents could have included corrected versions of the documents
that were not admitted into evidence at trial and additional
supplemental stipulations of the parties. Petitioner failed to
confer with respondent and then inexplicably failed to file a
brief or a reply brief. In the end, although provided ample
opportunity, petitioner has done little to help himself prevail
on the remaining issues.
I. General Deduction Rules
Deductions are a matter of legislative grace, and the
taxpayer must maintain adequate records to substantiate the
amounts of any deductions or credits claimed. Sec. 6001;
INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992); sec.
1.6001-1(a), Income Tax Regs.
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Last modified: March 27, 2008