- 3 - prepare a stipulation of facts and stated that the failure of either party to cooperate in the preparation of such stipulation could result in sanctions. The order also required each party to exchange documents that the party intended to use at trial and to prepare a pretrial memorandum and submit copies to the Court and opposing party at least 2 weeks before the first day of the trial session. By letter dated April 9, 2004, respondent’s Appeals officer scheduled a settlement conference with petitioner for May 25, 2004. When a settlement was not reached, petitioner’s case was returned to the Division Counsel’s office, and an attorney from that office scheduled an October 20, 2004, meeting with petitioner for the purpose of preparing a stipulation of facts for trial. Petitioner attended the meeting, but his documentation was incomplete. The parties did not prepare a stipulation of facts. On October 25, 2004, both respondent’s counsel and petitioner appeared at calendar call and were heard. Respondent’s counsel reported that respondent was ready to proceed with trial. Petitioner requested additional time to prepare and submit his Federal income tax returns for the years in issue. We ordered the parties to submit decision documents or a status report on or before November 24, 2004.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011