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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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