Gary L. Carnahan - Page 3

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               As required by the Court's Standing Pretrial Order, each               
          party submitted a trial memorandum, both of which the Court had             
          filed in this case.  In petitioner's trial memorandum, petitioner           
          indicated that he did not intend to call any witnesses at trial.            
          In respondent's trial memorandum, respondent indicated that she             
          did not intend to call any witnesses at trial.                              
               When this case was called from the calendar at the Court's             
          trial session in Carson City, Nevada, the parties informed the              
          Court that they had not entered into a stipulation of facts and             
          that neither party intended to call any witnesses.  Consequently,           
          the Court held a pretrial conference in this case, inter alia, to           
          ascertain from the parties why a trial should be held in this               
          case when neither party intended to call any witnesses.  At that            
          pretrial conference, petitioner indicated, inter alia, that it              
          was his position that, because respondent had conceded that a               
          Form 1099 in the amount of $6,791.10 had been erroneously re-               
          ported to the Service and erroneously included in respondent's              
          computation of the deficiency and additions to tax for peti-                
          tioner's taxable year 1991, the burden of proof in this case                


          3(...continued)                                                             
          Codega & Fricke reported two Form 1099 disbursements to the                 
          Service for petitioner's taxable year 1991, one in the amount of            
          $6,791.10 and a corrected one in the amount of $3,479 and (2) ad-           
          mitted the correctness of the allegation in petitioner's amended            
          petition that the Form 1099 issued by Codega & Fricke in the                
          amount of $6,791.10 was in error.                                           





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