-6-
motion were copies of respondent's July 20 and July 26, 1995,
letters, in which respondent had attempted to schedule meetings
with petitioner to prepare the case for trial and which had been
accompanied by a proposed stipulation of facts, an informal
request for information, a copy of Rule 91 of the Court's Rules
(concerning stipulations for trial), a copy of Publication 947,
and two copies of Form 2848. Petitioner returned these letters
to respondent stamped as follows:
REFUSED FOR CAUSE
WITHOUT DISHONOR
U.C.C. 3-501
DATE
Also on October 13, 1995, we issued another order in which
we noted that petitioner's objection and request for admissions
had continued the tax protester course that we had warned him
against. We rejected petitioner's tax protester arguments and
referred him to the recently issued opinion in Santangelo v.
Commissioner, T.C. Memo. 1995-468, which had rejected the
identical section 83 argument made by the taxpayer in that case.
We made absolute our order to show cause and thereby accepted as
established for the purposes of this case the facts set forth in
respondent's proposed stipulation of facts. We once more urged
petitioner to provide respondent's counsel with the documentation
supporting his asserted business expenses and itemized deductions
and to settle the case by agreement.
Our order of October 13, 1995, also instructed the Clerk of
the Court to return petitioner's request for admissions unfiled
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