Kamil F. and Nagwa Gowni - Page 28

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          Gownis should have reported this amount on their 1999 return as             
          income from self-employment.                                                
          Procedural Matters                                                          
               The Gownis and the Mansours filed their respective petitions           
          with the Court on May 3, 2002.  Included in the Mansours’                   
          petition was the following statement:                                       
                    5.  The facts upon which Petitioners rely, as the                 
               basis of their case, are as follows:                                   
                         *    *    *    *    *    *    *                              
                         d.  Petitioners’ [sic] can prove that the                    
               gross income they reported in 1996 through 1999                        
               represented their worldwide gross taxable income and                   
               that all other bank deposits constitute non-taxable                    
               income.                                                                
          The Gownis included a similar statement in their petition as to             
          the years 1998 and 1999.                                                    
               On April 22, 2003, the Court served on petitioners Notices             
          Setting Case for Trial.  Attached to the Notices Setting Case for           
          Trial was the Court’s Standing Pretrial Order.  The Standing                
          Pretrial Order provided, in pertinent part, as follows:                     
                    To facilitate 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                     
               solely to impeach the credibility of a witness.  * * *                 
               Any documents or materials which a party expects to                    
               utilize in the event of trial (except solely for                       
               impeachment), but which are not stipulated, shall be                   
               identified in writing and exchanged by the parties at                  
               least 14 days before the first day of the trial                        





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