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was in Missouri.
As of the time this case was called for trial on November
13, 1995, petitioner had completely failed to comply with this
Court's standing pretrial order and certain of its Rules (e.g.,
Rule 91).
At trial, petitioner initially refused to provide any
testimony as to relevant facts, and he did not present any
documents in support of his positions on the various issues in
this case. Upon questioning by the Court, petitioner conceded
that he received the dividend and interest income determined by
respondent and that he received gross receipts from the payors
determined by respondent. However, he testified that he could
not remember the amounts of such gross receipts. He also testi-
fied in general, conclusory, and/or vague terms about deductions
to which he claims he is entitled for the years at issue.
At the conclusion of the trial herein, the Court set a
briefing schedule under which simultaneous opening briefs were
due on January 12, 1996, and simultaneous answering briefs were
due on February 12, 1996. The Court also reminded petitioner
that the only record on which the Court would decide this case is
the record established at trial, which consists solely of peti-
tioner's testimony, and informed the parties that although the
record in this case had been submitted at trial, it was still
possible for the parties to attempt to settle the case. The
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