Stanley M. Kurzet and Anne L. Kurzet - Page 3

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            whether petitioners should be required to capitalize additional                           
            costs relating to the timber farm as part of the costs of a water                         
            reservoir).                                                                               
                  Unfortunately, pretrial, trial, and posttrial proceedings in                        
            this case are marked by miscommunication between the lawyers for                          
            the parties and by frequent allegations by one lawyer against                             
            another that there is misrepresentation of the facts and                                  
            evidence.  The inability of the parties' lawyers in this case to                          
            communicate effectively with each other resulted in the trial of                          
            issues that should have been settled and in the presentation of                           
            evidence and arguments in an untimely and confusing manner.                               
                  The Court spent hours with the parties' lawyers attempting                          
            to identify and articulate the various primary and alternative                            
            issues and arguments and the relationship of the issues to each                           
            other.  Similar to much of the miscommunication between the                               
            parties throughout the pretrial and trial, arguments made in the                          
            parties' posttrial briefs are filled with unnecessary accusatory                          
            statements.                                                                               
                  Unless otherwise indicated, all section references are to                           
            the Internal Revenue Code, and all Rule references are to the Tax                         
            Court Rules of Practice and Procedure.                                                    











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