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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.
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