Robert C. Curci - Page 3

                                        - 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