- 6 -
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
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011