- 13 -
photocopied. That conference was never held for reasons not
stated in the record.
F. Further Trial
1. Exchange of Documents
On July 19, 1996, these cases were again set for trial at
the next regular session of the Court in Atlanta, Georgia. We
again attached the standing pretrial order, as described above.
See paragraph I-E-1. In an attempt to ensure that the cases were
ready for trial, and to prevent recurrence of the problems just
described, the Court issued orders on July 10, July 19, July 24,
and October 7, 1996, requiring the parties to state their
position on each issue in the notice of deficiency, identify in
writing documents to be used at trial, exchange documents,
stipulate to them, and file pretrial memoranda earlier than
required by the standing pretrial order.
Respondent complied with the Court's orders. Petitioners
did not. Petitioners argued that respondent's agents had
harassed them. Petitioners attached copies of Court orders;
various motions filed by petitioners; documents related to Ms.
Feltrinelli's January 1996 surgery; petitioners' tax returns for
the years in issue; the notices of deficiency; a campaign
advertisement of Mr. Owens attacking the Internal Revenue Service
(IRS); copies of checks that Mrs. Owens wrote to the IRS in
December 1979, January 1982, September 1983, and 1985 (illegible
month), and that Ms. Feltrinelli wrote in October 1981; copies of
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