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(D) Under above stress conditions, the petition-
ers’ counsel talked into the petitioners to sign
the incomplete stipulation issues made up by the
respondent at the last minute on Feb. 6th, 1999 by
saying he could do the second phase work or he
would not represent the petitioners on the Feb.
8th, 1999 in the court.
(E) In the morning (About 9:00 A.M.) of Feb. 8th,
1999; Petitioner did turn in the above situation
paper and requested the Judge to consider the COGs
of 1992, 1993 and few expenses items which respon-
dent deliberately drop or cut off in respondent
issues two days ago. Showing the stipulations has
the figures made up by the respondent except the
taxable year of 1991. Starting from the end of
January 1999; The respondent just hold the pro-
gress of reviewing the taxable year of 1992 and
1993; Do not mention to exchange the documents or
provide the opportunity for petitioners until Feb.
6th, 1999. All the papers were prepared for last
minutes signatures. This was the way the profes-
sional designed the trap to take advantage of the
taxpayers unfairly by giving petitioners no oppor-
tunity at all saying the court need the signatures
to turn in. The petitioners did not sign the
stipulations of facts at the first place because
the respondent did not provide the complete ex-
penses report when reviewing the taxable year of
1991. I believe the laws give the taxpayers to
know how the deficiency being calculated and based
on. Respondent hold or hide the documentations
and provided no chance for petitioners to explain
or exchange are not only unfair, but, trying to
stop the court to review what figures respondent
made up deliberately to take advantage of the
petitioners is obviously seen. If the respondent
did not make up the figures or untruth report to
the court, respondent should not be afraid of any
questions to be asked by the Judge during the next
investigation. [Reproduced literally.]
We find petitioners’ motion and petitioners’ reply to be
vague and confusing. However, those filings do not appear to
suggest or argue that we had no jurisdiction over the subject
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