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issues. Respondent then orally conceded all the additions to
tax, a 1981 partnership loss item, and a 1981 capital loss item
resulting in a carryover to 1982. Respondent’s counsel
represented that this disposed of all the issues, except that
petitioner had advised him “approximately five minutes ago” of an
intent to raise another issue.
After some discussion as to petitioner’s contentions, the
following colloquy occurred:
THE COURT: You were prepared -- today was supposed to
be the trial, so you were prepared to offer whatever
evidence you need to offer on this matter, or do you think
that the evidence in the record is sufficient to enable you
to make your argument?
MR. ROBERTSON: I think what we have entered on the
record is sufficient, yes, I do.
Petitioner then filed (1) a Motion for Continuance to Remedy
Discovery Improperly Denied Petitioner, (2) a Motion for
Continuance due to Difficulty Stipulating, (3) a Motion for
Continuance to Subpoena Witnesses Necessitated by Belated Denial
of Transcript, (4) a Motion for Continuance to Obtain Transcript
Evidence Improperly Denied Petitioner, and (5) a Motion to Set
Aside Results of 1989 Hearing Made Defective by Lack of
Transcript. After oral argument, the Court denied all of these
motions for reasons set forth in the transcript of proceedings.
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