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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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