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other well-worn and long-rejected tax protester arguments.
Petitioner failed to file a return for 2001.
Respondent reconstructed petitioner’s income from third-
party reporting, including Forms W-2, Wage and Tax Statement,
issued to petitioner by “Julie K. McCammon, M.D.”, Forms 1099
issued for interest paid by banks, capital gain income, and
various “medical payments”. The wages included in respondent’s
determination were $325,304 for 2000, $214,114 for 2001, and
$256,811 for 2002. The items included in respondent’s
determinations of income were listed and identified in schedules
attached to the statutory notices for each year.
In the petition in each case, petitioner denied that she had
any tax liability, denied the income items, and claimed that she
had dependents, business expenses, deductions, credits, etc. She
did not, however, identify any specific items in dispute.
By notices served April 6, 2006, the three cases were set
for trial in Charleston, West Virginia, on September 11, 2006.
Attached to the notice of trial was a Standing Pretrial Order
that stated, among other things:
ORDERED that all facts shall be stipulated to the
maximum extent possible. All documentary and written
evidence shall be marked and stipulated in accordance
with Rule 91(b), unless the evidence is to be used
solely to impeach the credibility of a witness.
Objections may be preserved in the stipulation. If a
complete stipulation of facts is not ready for
submission at the commencement of the trial or at such
other time ordered by the Court, and if the Court
determines that this is the result of either party’s
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