Cliff Connors - Page 11

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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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