- 3 -
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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