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4. Delay
Petitioners failed to cooperate in discovery, which we can
(and do) consider as evidence of an intent to delay these
proceedings. See, e.g., Lipari v. Commissioner, T.C. Memo.
2000-280. In addition, we consider the following actions as
evidence of delay: Petitioners refused to stipulate the
authenticity of numerous documents to which petitioners could not
have entertained good faith doubts about such authenticity.
Petitioners refused to stipulate the notice, despite the fact
that they attached a copy of the notice to their petition. They
refused to stipulate their own tax return for 1991 and the tax
returns for Complete Connections Trust and J&R Trust,
notwithstanding that Rita Snyder personally had prepared the
returns and was familiar with them. They refused to stipulate to
Complete Connections Trust’s and J&R Trust’s bank records,
despite the fact that petitioners personally handled the two
trusts bank transactions and were familiar with them. As a
result, respondent was forced unnecessarily to produce
foundational witnesses to attest to the authenticity of these
records.
Petitioners refused to stipulate certain Government records,
such as deeds to their home, and business licenses for Complete
Connections Trust, which petitioners themselves completed and
submitted to the appropriate local agency. As a result,
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