Brian Hilvety - Page 6

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               miss for failure to properly prosecute this case.                      
                    Do you understand what I’m saying to you?                         
                    THE WITNESS:  Yes, I do.                                          
                    THE COURT:  Okay.  Now, what facts that are rele-                 
               vant to resolving the issues that remain in this case                  
               do you want to testify about?                                          
                    THE WITNESS:  In light * * * [of] what you’ve just                
               said, I have nothing else.                                             
               On cross-examination, the following dialogue took place                
          between respondent’s counsel and petitioner:                                
                    Q  Mr. Hilvety, you did not file a tax return for                 
               taxable year 1997, did you?                                            
                    A  I could not find in the Internal Revenue Code                  
               anywhere where I was required by law, written by Con-                  
               gress, to file a return.                                               
                    Q  Sir, did you or did you not file a tax return                  
               for 1997?                                                              
                  *       *       *       *       *       *       *                   
                    THE WITNESS:  No, I did not.                                      
               The Court did not order any posttrial briefs in this case.             
          Nonetheless, on March 26, 2003, petitioner submitted to the Court           
          a document that the Court had filed as petitioner’s supplement to           
          petitioner’s trial memorandum (petitioner’s supplement).  Peti-             
          tioner’s supplement contains questions, statements, contentions,            
          and arguments that the Court finds to be frivolous and/or ground-           
          less.  Petitioner’s supplement also argues for the first time               
          that respondent mailed the notice to him with respect to his                
          taxable year 1997 after the period of limitations prescribed by             





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