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notwithstanding the Court’s previous statement.” Respondent’s
counsel stated that he was not relying on any alternative
theories and would proceed on the assignment of income theory
reflected in the notices of deficiency. In response to the
Court’s inquiry, respondent declined to make any concession based
on community property income because “it’s not uncommon in this
state for professionals to have some arrangement with respect to
community property.” Petitioner declined to present evidence,
after being advised again by the Court that the stipulated bank
records satisfied the Government’s burden. Petitioner declined
to testify or to identify the person advising her on the
erroneous legalistic arguments set forth in her filings, citing
the Fifth Amendment. Petitioner did, however, identify her 1996
and 1997 renewal applications for her license with the Arizona
State Board of Chiropractic Examiners, which reflected her office
address as Canyon State Chiropractic.
Respondent’s motion to dismiss was taken under advisement,
and petitioner was advised that, while the Court was awaiting the
transcripts to be used in preparing this opinion, she might
respond to the motion, make an offer of proof, and present
records dealing with deductions to respondent’s counsel. Nothing
has been received from petitioner indicating that she has
abandoned her erroneous and frivolous positions in this case.
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Last modified: May 25, 2011