Carolyn M. Fankhanel - Page 26

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          Petitioner’s amended petition avers no particular facts with                
          respect to respondent’s numerous adjustments but, for the most              
          part, raises constitutional and other arguments that petitioner             
          later abandons.                                                             
               In December 1995, petitioner submitted three documents:                
          (1) Motion to Dismiss, (2) Motion to Compel a Constitutional                
          Guarantee, and (3) Request for Production of Documents and                  
          Things.  By order dated January 22, 1996 (the January 22 order),            
          the Court denied the two motions and returned the request.  The             
          January 22 order cautions petitioner:                                       
               Rather than relying on groundless constitutional                       
               arguments and misconceived notions about the Tax                       
               Court’s procedures, petitioner’s interests will be                     
               better served by continuing to confer with respondent’s                
               counsel in an attempt to settle this case and by                       
               following the instructions in the Court’s standing pre-                
               trial order * * *.                                                     
          The January 22 order also informs petitioner that she bears the             
          burden of proof and advises her to submit to respondent the                 
          documentary evidence to substantiate her assertions that                    
          respondent’s notice of deficiency is incorrect.                             
               This case was calendared for trial at a trial session of               
          this Court commencing on September 30, 1996.  On that date, a               
          hearing was held to determine whether the case was ready for                
          trial.  At that hearing, petitioner’s failures to cooperate with            
          respondent to prepare this case for trial were cataloged.                   
          Petitioner was instructed to meet with respondent’s counsel to              
          attempt a stipulation for trial.  That effort was unsuccessful,             




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