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Court’s order, but the District Court stayed incarceration
pending compliance with its orders. Thereafter, records were
finally produced, and the revenue agent’s questions were answered
by then recently retained counsel.
OPINION
The issue in these cases is whether certain trusts
established by the Haneys will be respected for tax purposes.
All other issues have been abandoned by petitioners’ failure to
address them in their briefs. Rule 151(e)(2), (4); Cluck v.
Commissioner, 105 T.C. 324, 325 n.1 (1995); Petzoldt v.
Commissioner, 92 T.C. 661, 683 (1989); Money v. Commissioner, 89
T.C. 46, 48 (1987); see Vetrano v. Commissioner, T.C. Memo. 2000-
128; Levert v. Commissioner, T.C. Memo. 1989-333, affd. without
published opinion 956 F.2d 264 (5th Cir. 1992). Questions
concerning the viability of the various trusts for tax purposes
are substantially resolved based on concessions expressly made in
petitioners’ filings, as quoted below. Petitioners’ concessions
have simplified this opinion, because making sense of the
extensive and internally contradictory record without the
assistance of well-organized proposed findings of fact from
either party would be an undue burden on the Court. See Stringer
v. Commissioner, 84 T.C. 693, 705 (1985), affd. without published
opinion 789 F.2d 917 (4th Cir. 1986).
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