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Requirements
To effectuate the foregoing policies and an orderly and
efficient disposition of all cases on the trial
calendar, it is hereby
ORDERED that all facts shall be stipulated to the
maximum extent possible. All documentary and written
evidence shall be marked and stipulated in accordance
with Rule 91(b), unless the evidence is to be used to
impeach the credibility of a witness. Objections may
be preserved in the stipulation. If a complete
stipulation of facts is not ready for submission at
trial, and if the Court determines that this is the
result of either party’s failure to cooperate fully in
the preparation thereof, the Court may order sanctions
against the uncooperative party. Any documents or
materials which a party expects to utilize in the event
of trial (except for impeachment), but which are not
stipulated, shall be identified in writing and
exchanged by the parties at least 15 days before the
first day of the trial session. The Court may refuse
to receive in evidence any document or material not so
stipulated or exchanged, unless otherwise agreed by the
parties or allowed by the Court for good cause shown. *
* *
Petitioner served on respondent a document entitled
“Interrogatories, Requests for Admission and Production of
Documents”. On October 10, 2001, respondent filed a motion for
protective order. On October 11, 2001, we issued an order
granting respondent’s motion, in which we stated:
The attachment to respondent’s motion, which includes a
copy of a document that petitioner served on
respondent, entitled “Interrogatories, Requests for
Admission and Production of Documents”, contains
contentions and/or statements by petitioner that the
Court finds to be groundless and/or frivolous. The
Court reminds petitioner that section 6673(a)(1) of the
Internal Revenue Code states in pertinent part:
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Last modified: May 25, 2011