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2 taxable years would soon be docketed, and it would conserve the
parties’ and Court’s time to try both cases together.
Petitioners joined in the motion to continue on the grounds that
it would provide time for the parties to further refine
documentary evidence.
A continuance was granted, and the Court provided the
parties with additional guidance regarding trial preparation,
including an admonition to spend the time in recess to prepare
the two cases for trial, including organizing documents and
interviewing witnesses.
In a status report filed on November 19, 2002, respondent
advised that petitioners’ 1995 and 1996 tax years were now in
issue (Case II) and that petitioners had been requested in
writing, as early as October 15, 2002, to begin the trial
preparation process. The adjustments to petitioners’ 1995 and
1996 tax years are substantially the same as those for
petitioners’ 1992, 1993, and 1994 tax years.4 As of the date of
respondent’s report, petitioners had not contacted respondent
regarding Case I or Case II.
On December 13, 2002, the Court’s notice setting cases for
trial on May 12, 2003, along with a standing pretrial order was
issued to the parties ordering, among other matters, the parties
4 The examination of petitioners’ 1992, 1993, and 1994 tax
years began during November 1995 and the examination of
petitioners’ 1995, and 1996 tax years began during November 1997.
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