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Rule 91(a) requires the parties to stipulate all evidence
that fairly should not be in dispute. Petitioner refused to
execute a written stipulation prepared by respondent that would
have placed into evidence copies of petitioner's Federal income
tax returns for the years at issue and copies of the notices of
deficiency for those years. These documents were admitted into
evidence over petitioner's objection. At the time the petitions
were filed, petitioner's legal residence was Las Vegas, Nevada.
Petitioner is a retired attorney. He was not engaged in the
practice of law during the years at issue. On his 1995 and 1996
Federal income tax returns, he reported wage and salary income as
well as income from a trade or business activity described as
insurance sales. The wage and salary income reported on the 1995
return came from two family and medical health plans for which
the employers issued Internal Revenue Service (IRS) Forms W-2,
Wage and Tax Statement. The wage and salary income reported on
the 1996 return was from an employer named IMC Trading, Inc.,
also based on an IRS Form W-2.
3(...continued)
deficiencies at issue in this case cannot be assessed until the
Court issues a decision. A "no change" letter issued by
respondent does not generally preclude respondent from
subsequently issuing a notice of deficiency. Opine Timber Co. v.
Commissioner, 64 T.C. 700, 712 (1975), affd. without published
opinion 552 F.2d 368 (5th Cir. 1977).
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