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solicited by counsel for respondent on cross-examination, and the
question generated no objection from petitioners’ counsel. That
testimony is then corroborated by copies of records maintained in
IRS computer systems with respect to Ms. Quinn’s 1999 return.
The records were offered as an exhibit by respondent’s counsel at
trial and were, after review, admitted without objection from
petitioners’ counsel.
Petitioners filed an objection to respondent’s motion for
leave to file amendment to answer. The 2-page document makes a
number of references to “dilatoriness” on the part of respondent
and contains repeated statements to the effect that respondent
has failed to offer reasons why amendment was not sought prior to
trial. Petitioners also allude generally to “prejudice”, but in
only one context do they expound upon such allegations with
anything that might be considered a more particularized
explanation of how they would be disadvantaged: “Respondent’s
dilatory motion will seriously impede the filing of Post-Trial
Briefs in this case, as Respondent’s Motion will not be decided
upon by this Court until after the submission of Petitioners’
Post-Trial Brief. Petitioners will therefore be prejudiced in
their compliance with this Court’s post-trial briefing schedule.”
Petitioners further suggest that their cooperation should have
bearing on our disposition of the motion.
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Last modified: November 10, 2007