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