Thomas G. Brenner - Page 6

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                                    Requirements                                      
               To effectuate the foregoing policies and an orderly and                
               efficient disposition of all cases on the trial                        
               calendar, it is hereby                                                 
               ORDERED that all facts shall be stipulated to the                      
               maximum extent possible.  All documentary and written                  
               evidence shall be marked and stipulated in accordance                  
               with Rule 91(b), unless the evidence is to be used to                  
               impeach the credibility of a witness.  Objections may                  
               be preserved in the stipulation.  If a complete                        
               stipulation of facts is not ready for submission at                    
               trial, and if the Court determines that this is the                    
               result of either party’s failure to cooperate fully in                 
               the preparation thereof, the Court may order sanctions                 
               against the uncooperative party.  Any documents or                     
               materials which a party expects to utilize in the event                
               of trial (except for impeachment), but which are not                   
               stipulated, shall be identified in writing and                         
               exchanged by the parties at least 15 days before the                   
               first day of the trial session.  The Court may refuse                  
               to receive in evidence any document or material not so                 
               stipulated or exchanged, unless otherwise agreed by the                
               parties or allowed by the Court for good cause shown. *                
               * *                                                                    
               Petitioner served on respondent a document entitled                    
          “Interrogatories, Requests for Admission and Production of                  
          Documents”.  On October 10, 2001, respondent filed a motion for             
          protective order.  On October 11, 2001, we issued an order                  
          granting respondent’s motion, in which we stated:                           
               The attachment to respondent’s motion, which includes a                
               copy of a document that petitioner served on                           
               respondent, entitled “Interrogatories, Requests for                    
               Admission and Production of Documents”, contains                       
               contentions and/or statements by petitioner that the                   
               Court finds to be groundless and/or frivolous.  The                    
               Court reminds petitioner that section 6673(a)(1) of the                
               Internal Revenue Code states in pertinent part:                        








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