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failure to fully cooperate 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 solely
for impeachment), but which are not stipulated, shall
be identified in writing and exchanged by the parties
at least 14 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. * * *
On June 5, 2006, the Court received from petitioner a letter
in which she referred to the three docketed cases and stated:
The docket numbers and tax years appear to be mixed up.
Would you please explain to me which docket number
applies to which tax year.
This case should be settled. If the IRS would
stipulate as to my business expenses, I will stipulate
as to the gross receipts and we can settle this case
out of court.
In response to that letter, the Court issued an order dated
June 6, 2006, which set out the docket numbers, years,
deficiencies, and additions to tax and penalties in issue. The
order continued:
The substantial deficiencies in issue in these
cases arise from respondent’s determination that
petitioner failed to report income for the years in
issue. As petitioner argues, no allowance has been
made for business expenses that would be normal under
such circumstances. However, despite petitioner’s
claims of uncertainty, amounts determined to be her
income are specified in the notices of deficiency sent
to her for the years in issue as attributable to
reporting by third-party payors. In any event, it
appears that the within cases contain common issues.
Upon due consideration and for cause, it is hereby
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