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refused to stipulate a single fact or document in the
stipulation. Many of the facts stated in the stipulation were
foundational and indisputable. For instance, the first three
stipulations were: (1) “Petitioner is Letantia Bussell, whose
residence address was 2285 Worthing Lane, Los Angeles, California
90077, on the date the petition was filed”; (2) “The statutory
notice of deficiency upon which this case is based was mailed to
the Petitioner on June 28, 2002. Attached and marked as Exhibit
1J is a true and correct copy of said notice”; and (3)
“Petitioner, Letantia Bussell, was married to John Bussell during
taxable years 1983 through 2002”. Most of the documents in the
stipulation were public and business records regarding the three
corporations.
Respondent sent petitioner two supplemental stipulations of
fact in March 2004 which contained other facts and more public
and business records relating to BBL (supplemental stipulations I
and II). These records had been prepared and maintained by
Berson. Petitioner refused to stipulate a single fact or
document contained in supplemental stipulations I and II.
On March 5, 2004, respondent moved the Court under Rule
91(f)(1) to order petitioner to show cause why the matters
included in the stipulation should not be established as fact.
Respondent did not include with this motion any of the matters
addressed in supplemental stipulations I and II. The Court
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