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properly to prosecute these cases, with decisions
entered in the full amounts of deficiencies, additions
to tax, and penalties determined in the statutory
notices. Such showing shall include (1) a
representation that, on or before October 23, 2006,
petitioner delivered to respondent’s counsel, or to a
designee of respondent’s counsel, all documents
identifying or substantiating deductions, exemptions,
or credits to which petitioner claims entitlement for
tax years 2000, 2001, and 2002 and (2) a report with
respect to items remaining in dispute after
respondent’s response ordered hereinbelow. Such report
shall include copies of all documents relating to the
items remaining in dispute, identification of witnesses
that petitioner would call at any further trial of
these cases, a summary of the testimony of each such
witness, and an estimate of the time required for such
testimony. It is further
ORDERED: That, on or before November 22, 2006,
respondent shall advise petitioner in writing with
respect to any deductions, exemptions, or credit that
respondent will allow for the years in issue based on
the material produced to respondent by petitioner no
later than October 23, 2006. It is further
ORDERED: That, on or before December 11, 2006,
respondent shall serve on petitioner and file with the
Court a written report as to respondent’s then position
as to further proceedings in these cases.
The parties are advised that further trial of
these cases, if appropriate, may be set in Washington,
D.C., as indicated at the hearing on September 11,
2006, or, if the parties agree, may be set in
Louisville, Kentucky, during the Trial Session of the
Court scheduled to commence there on February 5, 2007.
Petitioner failed to comply with the Court order of
September 11, 2006. She did not present to respondent any
substantiation of expenses claimed. She did provide copies of
unsigned Forms 1120S, U.S. Income Tax Return for an S
Corporation, for the periods ended December 31, 2000;
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