Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 50




                                       - 50 -                                         
               Petitioner first complains of respondent’s attempts to                 
          prevent or thwart petitioner’s discovery.  Petitioner has failed            
          to support that complaint with any proposed findings of fact.               
          Petitioner next complains of respondent’s failure to comply with            
          requests for discovery from June 1990 through the middle of 1994.           
          By the motion for sanctions, on July 22, 1994, the petitioning              
          partners moved for sanctions on account of alleged discovery                
          abuses and violations by respondent.  We denied the motion for              
          sanctions in its entirety.  Petitioner’s proposed finding of fact           
          in support of this claim does not bring to our attention anything           
          new.  Petitioner’s complaints that respondent hampered                      
          petitioner’s presentation in the hearing and failed to stipulate            
          facts in anticipation of the hearing are also unsupported by the            
          record.                                                                     
               Petitioner’s final claim, that, during the hearing,                    
          respondent introduced false and misleading testimony, is                    
          supported by the following proposed finding of fact:  “Respondent           
          allowed false and misleading testimony from Sterquell to be                 
          introduced.”  In support of that proposed finding of fact,                  
          petitioner’s only reference to the record is a reference to                 
          petitioner’s motion, made during the hearing, to strike testimony           
          (of Mr. Sterquell) and reconsider ruling that privilege was                 
          waived (motion to strike).  We denied the motion to strike.                 








Page:  Previous  34  35  36  37  38  39  40  41  42  43  44  45  46  47  48  49  50  51  52  53  Next

Last modified: May 25, 2011