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continuances would be granted. Petitioner and respondent
thereupon entered into a bare bones stipulation of facts,
agreeing only that petitioners resided in Reno, with attached
hard copy of petitioners' return and copy of the statutory notice
of deficiency. The only documentation that was presented by
petitioner and admitted into evidence at trial were examples of
brochures and other printed materials that petitioner produced
for clients of his advertising business during the taxable year.
Petitioner asserted over the years prior to trial and at trial
that he had documentary evidence to support the claimed
deductions. Although a day or two before trial petitioner had
finally obtained from storage the boxes in which--he told
respondent and the Court--his records were located, at trial
petitioner produced no profit and loss statements, no journals or
ledgers reflecting income and expenses, and no invoices,
receipts, or canceled checks documenting payments to vendors of
goods or services received by his business during the taxable
year. Nor did petitioner produce and submit any such documentary
evidence to respondent for inclusion in a supplemental
stipulation of facts during the 30-day period following the trial
that the record was held open to allow him to do so.
The Court set a seriatim briefing schedule, with respondent
to file the first brief. On August 10, 1998, following enactment
of the IRS Restructuring and Reform Act of 1998, Pub. L. 105-206,
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