- 3 - years. The deficiencies were based in large part upon respondent’s determination that petitioner received unreported income during those years. On September 23, 1999, petitioner filed a petition with this Court disputing the full amount of the deficiencies and penalties. Petitioner at that time resided in Riverside, California. Respondent then answered the petition and further set forth specific allegations of fact in support of the fraud penalties. Petitioner’s subsequent reply denied nearly all of respondent’s affirmative allegations and maintained that petitioner’s tax reporting was “full and accurate”. After close of the pleadings this case was set for trial, and copies of the Court’s standing pretrial order were served on the parties. Therein, petitioner and respondent were directed to begin discussions as soon as practicable, to stipulate facts to the maximum extent possible, and to submit trial memoranda if a basis of settlement could not be reached prior to trial. The pretrial order also warned generally that any unexplained failure to comply with its provisions could result in sanctions, including dismissal, and stated specifically that failure to cooperate in the stipulation process was a potential ground for such sanctions. On November 3, 2000, at which time this case was calendared for trial beginning on March 19, 2001, respondent’s counsel wrotePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011