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March 20, 1997, setting her case for trial on June 9, 1997.
Attached to the notice of trial was the Court's standing pretrial
order which states in part:
ORDERED that all facts shall be stipulated to the
maximum extent possible. All documentary and written
evidence shall be marked and stipulated in accordance
with Rule 91(b), unless the evidence is to be used to
impeach the credibility of a witness. Objections may
be preserved in the stipulation. If a complete
stipulation of facts is not ready for submission at
trial, and if the Court determines that this is the
result of either party's failure to fully cooperate in
the preparation thereof, the Court may order sanctions
against the uncooperative party. Any documents or
materials which a party expects to utilize in the event
of trial (except for impeachment), but which are not
stipulated, shall be identified in writing and
exchanged by the parties at least 15 days before the
first day of the trial session. The Court may refuse
to receive in evidence any document or material not so
stipulated or exchanged, unless otherwise agreed by the
parties or allowed by the Court for good cause shown.
Petitioner failed to comply with the Court's order to
stipulate her documentary evidence. As a result, the record in
this case does not contain any receipts which support her claimed
business expense deductions.4 We find that petitioner has failed
to meet her burden of proving her entitlement to the claimed
deductions. Rule 142(a).
After reviewing the record, we find it insufficient to allow
us to make an estimate of petitioner's deductible business
4 We refuse to rely on petitioner's self-serving written
statement describing the costs of her trip to Europe in 1992
because it is not corroborated by any canceled checks, receipts,
or other written documents. Niedringhaus v. Commissioner, 99
T.C. 202, 219-220 (1992); Tokarski v. Commissioner, 87 T.C. 74,
77 (1986).
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