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counsel immediately to discuss his concerns. Petitioner did not
respond to this letter.
On June 12, 2003, respondent’s counsel called petitioner and
left a message asking that petitioner telephone to discuss the
stipulation of facts. On June 12, 2003, petitioner left
respondent’s counsel a message to the effect that he would not
sign the stipulation because he did not agree with it. On
June 12, 2003, respondent’s counsel left petitioner a message
asking that petitioner meet at 10:00 a.m. on June 13, 2003, to
prepare a stipulation of facts that petitioner would be willing
to sign. On June 13, 2003, petitioner telephoned respondent in
the afternoon and left a message that he was unable to meet that
morning because he had just received respondent’s message
requesting the meeting.
On Sunday, June 15, 2003, petitioner submitted to respondent
a Form 1040, U.S. Individual Income Tax Return, for 1999. In
addition to claiming basis in the stock that he had sold and that
had been determined in the notice of deficiency to result in
capital gains, petitioner claimed bad debt losses of $260,770.
When the case was called for trial on June 16, 2003,
petitioner presented for the first time various documents that
had been requested by respondent and ordered produced by the
Court’s order of May 6, 2003. He did not present any canceled
checks supporting the alleged bad debt losses. He presented
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