- 23 -
are shams and that he did not show that he had bad debts in 1998.
Petitioner’s arguments for summary judgment lack merit.
3. Review Jeopardy Assessments
Petitioner in essence asks us to reconsider orders of this
Court dated June 2 and July 27, 1995, denying his motions to
review respondent’s jeopardy assessments. Petitioner contends
that the jeopardy assessments are invalid because, to make them,
respondent used data which would have been inadmissible under the
Federal Rules of Evidence if offered as evidence at trial. We
disagree for reasons stated at paragraphs A-2 and B-2, above.
4. Reconsideration of Order Deeming Matters Stipulated
Under Rule 91(f)
In his posttrial brief, petitioner requested that we
reconsider our pretrial order deeming certain documents and facts
stipulated. Respondent had moved to compel stipulation of facts
under Rule 91(f) on February 16, 2001. Respondent requested that
we should deem stipulated copies of the notice of deficiency,
petitioner’s income tax returns for 1985 and 1986, documents from
the U.S. Treasury and Republic Bank, schedules showing
petitioner’s income from accounting services, loans and check
cashing based on the computer records, on petitioner’s other
records, and on records from third parties, and the judgment from
petitioner’s criminal case. Respondent also requested that we
deem stipulated that petitioner did not file an income tax return
for 1987, the 13 corporations did not file Federal or State
Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: May 25, 2011