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corporate tax returns, and petitioner used false EINs for the 13
corporations.
We ruled on respondent’s motion following a pretrial
hearing. At the hearing, respondent showed sources, reasons, and
bases for facts and exhibits that we deemed stipulated, and
showed that petitioner had reasonable access to those sources or
bases for stipulation. Petitioner did not show any sources,
reasons, or bases for refusing to stipulate to those exhibits and
facts. We granted respondent’s motion in large part, but we
denied it to the extent that respondent had not produced
underlying documents relating to summaries. Summaries not deemed
stipulated were later admitted at trial after respondent provided
those underlying documents. See paragraph B-2, above.
Petitioner contends that we should reconsider our order
partially granting respondent’s motion to compel stipulation of
facts under Rule 91(f). We disagree. Petitioner’s reasons to
oppose stipulation are the same as those that he raised in his
request for summary judgment and review of the jeopardy
assessment, and in his post-trial briefs. We rejected those
arguments in paragraphs F-2 and F-3, above. We conclude that
reconsideration is not warranted here.
5. Conform Pleadings to Evidence
Petitioner contends that the pleadings in this case should
be conformed to the evidence under Rule 41(b).
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