- 28 - 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 trialPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011