Karol Z. Widemon - Page 5

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          rental expenses or capital loss carryovers.  Petitioner did not             
          call respondent’s counsel to reschedule, nor did she appear for             
          the conference.                                                             
               At calendar call, respondent’s counsel informed the Court              
          that he had been unsuccessful in obtaining a response from                  
          petitioner regarding a proposed stipulation of facts.  Petitioner           
          contended that she had signed a stipulation of facts at the prior           
          trial session and that the document had been filed with the                 
          Court.  The records of the Court, including the file in this                
          case, show no record of any stipulation of facts having been                
          filed, and the Court so informed petitioner.                                
               Petitioner also contended that respondent had improperly               
          attempted to raise new matters in the proposed stipulation of               
          facts by requesting substantiation for the capital loss                     
          carryovers and the rental expenses petitioner claimed on the                
          return submitted after she received the notice of deficiency.               
               At trial, petitioner reiterated her contention that a                  
          stipulation of facts had been filed with the Court at the initial           
          trial session and that respondent was attempting to raise new               
          matters.  Petitioner did not have a signed copy of the                      
          stipulation of facts that she alleged had been submitted to the             
          Court.                                                                      
               At the conclusion of trial, petitioner requested 1 week to             
          submit a brief on the issues.  The Court advised petitioner that            






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