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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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