- 9 -
income' or 'liability' under a revenue law for any calendar
year."
(9) In request 21, respondent asserted that petitioner
informed the IRS special agents that he earned no income in 1986
and was not required to file a return for that year. In
response, petitioner explained that he "did not state that he had
'earned no income', although this may be factual; but petitioner
had no 'earned income' or items amounting to income to the best
of his knowledge and belief."
(10) In requests 22 and 23, respondent asserted that
petitioner advised his clients to claim the foreign earned income
exclusion on their returns and that none of petitioner's clients
actually resided or worked outside the United States during 1984,
1985, or 1986. In response, petitioner stated that respondent
failed to define the terms "client", "resided", and "United
States".
On January 19, 1996, the parties were notified that this
case was scheduled for trial on June 17, 1996, in San Diego,
California. When the case was called on June 17, 1996,
petitioner made an oral motion for continuance for the purpose of
obtaining discovery, which was denied. Respondent then filed a
motion to impose sanctions upon petitioner, pursuant to Rule
104(c), for failure to comply with our May 9, 1996, order that
petitioner respond to the requests for admission. Petitioner
objected and argued against respondent's motion for sanctions.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011