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Petitioner resided in Aurora, Colorado, when her petition in this
case was filed.
On April 29, 2004, we received the parties’ signed decision
document, which we filed as the parties’ stipulation of
settlement. On May 7, 2004, we filed petitioner’s motion. On
August 6, 2004, we filed respondent’s response to petitioner’s
motion. On September 15, 2004, we filed petitioner’s reply to
respondent’s response and an additional declaration in support of
the reply. On December 6, 2004, we ordered petitioner to submit
an additional declaration and supporting documentation to support
the reasonableness of the costs claimed. On January 10, 2005, we
received and filed petitioner’s supplemental declaration, and on
January 27, 2005, we received and filed respondent’s supplemental
response to petitioner’s supplemental declaration.
Neither party requested a hearing, and, after reviewing the
relevant documents, we conclude that a hearing on this matter is
not necessary. See Rule 232(a)(2). In disposing of this motion,
we rely on the parties’ filings and attached exhibits.
Background
In 1984, petitioner and her husband, Bruce Bulger (Mr.
Bulger), invested in a partnership called Shorthorn Genetic
Engineering 1985-2, Ltd. (SGE), which had been organized,
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the petition, and all Rule references are to the Tax Court Rules
of Practice and Procedure.
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