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determination that he had taxable income in the amounts stated in
the notice of deficiency was in error. In the amended petition,
petitioner asserted that the notice of deficiency was invalid
because “the Internal Revenue Service failed to execute an
involuntary return as required by the IR Code.”
On October 5, 2001, the Court sent the parties a notice
setting the case for trial at the trial session of the Court in
Jacksonville, Florida, beginning on March 11, 2002. Accompanying
that notice was the Court’s Standing Pre-Trial Order, which
states in pertinent part as follows:
Policies
You are expected to begin discussions as soon as
practicable for purposes of settlement and/or
preparation of a stipulation of facts. Valuation
cases and reasonable compensation cases are generally
susceptible of settlement, and the Court expects the
parties to negotiate in good faith with this objective
in mind. All minor issues should be settled so that
the Court can focus on the issue(s) needing a Court
decision.
* * * * * * *
If difficulties are encountered in communicating with
another party, or in complying with this Order, you
should promptly advise the Court in writing, with copy
to each other party, or in a conference call among the
parties and the trial judge.
If any unexcused failure to comply with this Order
adversely affects the timing or conduct of the trial,
the Court may impose appropriate sanctions, including
dismissal, to prevent prejudice to the other party or
imposition on the Court. Such failure may also be
considered in relation to disciplinary proceedings
involving counsel. See Rule 202(a).
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Last modified: May 25, 2011