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mailing address.2 Petitioner informed the Court that he intended
to confer with respondent's counsel regarding stipulations and
requested that the case be recalled so that he might do so. The
Court granted his request, directed the parties to meet and
review whatever documents and information petitioner wanted to
present, and ordered that the case be recalled for a report
and/or trial on September 14, 1998.
On September 14, 1998, the case was recalled. Neither of
petitioners appeared. Respondent's counsel reported that
petitioner had met with respondent's counsel on Friday, September
11 and on Sunday, September 13. On September 11, petitioner did
not have any documentation with him, despite several earlier
requests that he produce whatever documents he had to support his
return positions and despite the Court's Standing Pre-Trial
Order, which required the parties to exchange documents at least
15 days before the beginning of the trial session. On September
13, petitioner finally presented some documentation purporting to
demonstrate his entitlement to the deductions and exemptions at
issue in this case. According to respondent's counsel, some of
the documents were clearly personal in nature, and the remaining
documents were not organized to facilitate review. After
approximately 4 hours, respondent's counsel offered petitioners
2At the calendar call on Sept. 8, 1998, petitioner notified
the Court of his new address.
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