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On June 7 and 15, 2000, petitioner filed a motion in limine
and a motion to strike, respectively. In these motions,
petitioner sought to exclude from evidence the declaration of the
Appeals officer and the exhibits attached thereto. On June 30,
2000, respondent filed responses objecting to these motions. The
Court subsequently denied both petitioner’s motion in limine and
motion to strike.
On June 28, 2001, petitioner filed a reply to respondent’s
response to petitioner’s motion for costs. Petitioner argued,
among other things, that at the time respondent sent the notice
of deficiency to petitioner, petitioner had already provided
respondent with enough documentation to resolve the issues
conclusively in favor of petitioner.
On July 2, 2001, petitioner filed a supplement to his reply
to respondent’s response to petitioner’s motion for costs. The
supplement reiterated his request for an award of reasonable
administrative and litigation costs, and also detailed a summary
of litigation costs totaling $6,610.45 incurred between June 2000
and June 2001. Presumably, this request for costs was in
addition to his previous request of $2,335.11, which he
previously made in his supplement to his motion for costs filed
on March 31, 2000.
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