- 13 - inappropriate, and a waste of time, and that we would consider any such arguments in deciding the motion to impose sanctions under section 6673. Following the trial, we directed the parties to prepare and submit a supplemental stipulation of facts and to address the application of section 1034. Although the supplemental stipulation of facts makes no mention of section 1034, and neither party made any arguments regarding section 1034 in their posttrial memoranda, we address the effect of section 1034 on petitioner’s sale of property in the opinion that follows because section 1034 affects the computation of gain from the sale of petitioner’s Rose Point Lane property. On June 28, 2004, petitioner’s posttrial memorandum was filed. In the posttrial memorandum, petitioner argued that “respondent has refused at all times verbally or upon documents to set forth any laws which authorizes [sic] him to take the actions or make claims for his process of income tax assessments” and that “it is self evident that nothing within the language of the respondent’s Supplemental Stipulations of Facts is based upon any United States tax law, statutes or regulations.” Petitioner also continued to advance arguments regarding the tax treatment of personal labor in his posttrial memorandum. On July 28, 2004, we filed petitioner’s answering posttrial memorandum, which contained 27 pages of tax-protester arguments similar to thosePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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