Steven J. and Jean L. Liddane - Page 5

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          jurisdiction, and set the case for trial at the Court's March 16,           
          1998, Portland, Oregon, trial session.                                      
               On March 2, 1998, respondent's and petitioners' trial                  
          memoranda were received by the Court.  In due course, they were             
          filed as part of the record in this case.  Petitioners' trial               
          memorandum contains an index of citations of more than 60                   
          authorities that includes, in addition to the Internal Revenue              
          Code, IRS Publication 17, the 1992 instructions for Form 1040,              
          Bouvier's Law Dictionary, 48 American Jurisprudence, 5 State                
          court opinions, 30 opinions of the U.S. Supreme Court, and 21               
          opinions of lower Federal courts.  Petitioners' trial memorandum            
          charges respondent's notice of deficiency with failure to cite              
          legal authority in support of its determinations, including the             
          failure to explain, in support of their objection to the                    
          additions, why filing income tax returns is “mandatory”.                    
               At the hearing of this case, the Court provided respondent's           
          counsel and petitioners with copies of the Court's opinion in               
          Cocozza v. Commissioner, T.C. Memo. 1997-305, with citations                
          of other such cases decided by the Court, including Talmage v.              
          Commissioner, T.C. Memo. 1996-114, affd. without published                  
          opinion 101 F.3d 695 (4th Cir. 1996).  Respondent's counsel                 
          informed the Court that he had already provided petitioners with            
          a copy of the Court's opinion in Talmage, as well as copies of              
          the Court's opinions in Greenberg v. Commissioner, 73 T.C. 806              





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