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asserted that the Tax Court rule regarding stipulation “runs
afoul of the Fifth Amendment.” During the conference telephone
call with the parties, the Court advised petitioner that she
faced several problems in this case, including the necessity of
showing that the bank deposits in issue were not payment for her
services and that income received by the chiropractic clinic
should be treated as community property. The Court further
advised her that business deductions to which she might be
entitled had not been allowed and that penalties were likely to
be imposed because this case appeared to be similar to other
recent cases involving similar facts. Petitioner insisted that
respondent had the burden of proof. The Court indicated that
respondent could satisfy his burden by introducing the bank
records into evidence. Petitioner stated that the records
relating to the deductions were in storage. The Court suggested
that, if petitioner made a good faith attempt to secure the
records and to abandon the meritless arguments previously made by
her, then, and only then, the Court would consider a continuance
of the case. Petitioner stated that she would contact
respondent’s counsel concerning the matters discussed.
After the conference telephone call, the Court’s order to
show cause was made absolute. On January 18, 2002, the Court
received from petitioner a Motion to Continue, in which
petitioner repeated her erroneous legal arguments. In addition,
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