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should be very specific and detailed. “[H]e is going to have to
show that he provided specific information to specific
professionals about the facts of the 2002 situation, not just
that he had an impression based on what occurred before that.”
Petitioner was also directed that any motion for leave to amend
the petition regarding additional issues that petitioner wanted
to raise that had not yet been pleaded, such as deductions, be
filed by May 22, 2006. Neal was told at trial that
Mrs. Connors’s testimony needed to be substantiated by documents
showing what petitioner paid for the support of his sons, what
the custody arrangements were in 2002, and whether there were any
agreements regarding support. He was told that he also needed to
include in the offer of proof applicable caselaw to support the
claims for deductions, exemptions, and credits.
Petitioner’s motion to amend the petition and petitioner’s
offer of proof were filed on May 19, 2006. The proposed amended
petition failed to identify any specific deductions to which
petitioner would be entitled, failed to contain clear and concise
assignments of error on the part of respondent or any clear and
concise statements of fact on which petitioner based an
assignment of error, and failed to allege any specific facts with
respect to the additions to tax. The proposed amended petition
disputed the taxability of the insurance benefits and stated:
The facts upon which the petitioner relies, as the
basis of petitioner’s case, are as follows: Taxes are
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