- 26 - 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,Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011