Clyde E. Owens and Marie W. Owens - Page 13

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          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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