- 5 - 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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011