Walter Van Eck and Friedgard Van Eck - Page 9

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          respondent's responsibility to show that petitioners received an            
          item of income, were not entitled to a deduction, or are subject            
          to the additions to tax.  That, of course, is not so.  See Rule             
          142(a).  Walter has had legal training.  He was advised by the              
          Court to pay close attention to our Rules.  At various times,               
          both the Court and respondent's counsel have tried to give                  
          petitioners, who represent themselves, help in understanding and            
          complying with the procedures and formalities for preparing,                
          trying, and briefing their case.  We cannot, and will not,                  
          however, excuse or overlook petitioners' failure to abide by our            
          Rules or to understand some of the basic and fundamental aspects            
          of bringing a case in the Tax Court.  Petitioners' apparent                 
          failure to understand their obligation to prove their case                  
          imposes risks that they must bear.                                          
          Income Items in Dispute                                                     
               The parties have stipulated to, or conceded at trial or on             
          brief, numerous issues that relate to respondent's bank deposit             
          analysis.  The parties have stipulated to the amounts that are in           
          dispute under respondent's bank deposit analysis.  They have                
          prepared an exhibit (Exhibit 201-GK) setting forth those amounts            
          and certain other amounts that were not deposited in any bank               
          account but that are in dispute between the parties.  We have               
          reproduced Exhibit 201-GK as an appendix.  We accept that the               
          items on Exhibit 201-GK are the remaining items of income that              
          are in dispute and that we must determine.  We have grouped those           

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