Lidia Lamanna - Page 3

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          claimed on Schedule E of petitioners’ jointly filed Federal                 
          income tax returns for 1986 through 1991.                                   
               Frank Lamanna and Lidia Lamanna each filed a petition with             
          this Court.  At the time the petitions were filed petitioners               
          resided in Los Angeles, California.  Respondent filed an answer             
          to each petition and later filed a motion to consolidate for                
          trial, briefing, and opinion.  On January 20, 2000, we granted              
          respondent’s motion to consolidate.                                         
               These consolidated cases were originally set for trial on              
          January 24, 2000.  Petitioners moved for a continuance on four              
          separate occasions, based on a variety of grounds, including but            
          not limited to an opportunity for petitioners to engage counsel.            
               These cases were set for trial at the trial session                    
          beginning May 13, 2002.  The parties executed on May 13, 2002, a            
          stipulation of settled issues that covered all taxable years in             
          issue.2  The stipulation, filed on May 14, 2002, set forth                  
          numerous adjustments that resulted in no deficiencies, no                   
          additions to tax, and no penalties for taxable years 1987 through           
          1991.  For 1986, the remaining taxable year, the stipulation                
          provided in pertinent part:                                                 





               2  While there are two docketed cases before the Court,                
          there is one stipulation of settled issues which addresses all              
          issues in each of these consolidated cases.                                 




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