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advised petitioners of the necessity of presenting documentation
that would substantiate the deductions to which they might be
entitled for the 3 years in issue. Thereafter, the Court
received from petitioners documents demanding production of
copies of subscribed oaths of office; their demands were
untimely, were not relevant to the subject matter involved in the
pending cases, and were not likely to lead to the discovery of
admissible evidence. On January 14, 2002, petitioners filed a
Motion to Dismiss claiming that neither respondent nor the Court
had “proven jurisdiction” in these cases. That motion was
denied. The Court has jurisdiction in these cases as a result of
timely filed petitions from valid notices of deficiency. Secs.
6212, 6213, and 6214. After invoking our jurisdiction in a
deficiency case, petitioners may not just change their minds and
decide they do not want to be here. Stevens v. Commissioner, 709
F.2d 12 (5th Cir. 1983), affg. T.C. Memo. 1982-352; Dorl v.
Commissioner, 57 T.C. 720 (1972), affd. per curium 507 F.2d 406
(2d Cir. 1974); see also sec. 7459(d); Estate of Ming v.
Commissioner, 62 T.C. 519 (1974) (a deficiency case commenced by
a taxpayer cannot be voluntarily dismissed without entry of a
decision on the merits).
On January 16, 2002, Respondent’s Motion in Limine to
Exclude Untimely Identified Witnesses and Untimely Exchanged
Documents was filed. That motion recounted petitioners’
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