-4-
v. Commissioner, 62 T.C. 519, 521 (1974) (citing Dorl v.
Commissioner, 57 T.C. 720, 721-722 (1972)), establish that a
taxpayer may not unilaterally oust the Tax Court from
jurisdiction which, once invoked, remains unimpaired until the
Court decides the case. We warned petitioner that section 6673
authorizes the Court to impose a penalty for groundless and
frivolous filings by taxpayers. Our order urged petitioner to
confer with respondent's counsel and submit to her documentary
evidence to substantiate his assertions about business expenses
and itemized deductions.
On September 18, 1995, respondent filed a Motion To Show
Cause Why Proposed Facts In Evidence Should Not Be Accepted As
Established. Because petitioner had failed to confer with
respondent about entering into a stipulation of facts in
accordance with Rule 91, respondent moved that a proposed
stipulation of facts that respondent had prepared should be
accepted as established. Respondent's proposed stipulation set
forth each of the individual items of income that respondent
attributed to petitioner; attached thereto was a descriptive list
of the sources and locations of the evidence supporting the facts
in the proposed stipulation, making it clear that the critical
assertions about the items of income were derived from
information returns received by respondent from payors. The
proposed stipulation also stated that petitioner is liable for
self-employment tax and is entitled to the filing status of
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