Julie K. McCammon - Page 4

                                        - 4 -                                         
               failure to fully cooperate in the preparation thereof,                 
               the Court may order sanctions against the uncooperative                
               party.  Any documents or materials which a party                       
               expects to utilize in the event of trial (except solely                
               for impeachment), but which are not stipulated, shall                  
               be identified in writing and exchanged by the parties                  
               at least 14 days before the first day of the trial                     
               session.  The Court may refuse to receive in evidence                  
               any document or material not so stipulated or                          
               exchanged, unless otherwise agreed by the parties or                   
               allowed by the Court for good cause shown.  * * *                      
               On June 5, 2006, the Court received from petitioner a letter           
          in which she referred to the three docketed cases and stated:               
               The docket numbers and tax years appear to be mixed up.                
               Would you please explain to me which docket number                     
               applies to which tax year.                                             
               This case should be settled.  If the IRS would                         
               stipulate as to my business expenses, I will stipulate                 
               as to the gross receipts and we can settle this case                   
               out of court.                                                          
          In response to that letter, the Court issued an order dated                 
          June 6, 2006, which set out the docket numbers, years,                      
          deficiencies, and additions to tax and penalties in issue.  The             
          order continued:                                                            
                    The substantial deficiencies in issue in these                    
               cases arise from respondent’s determination that                       
               petitioner failed to report income for the years in                    
               issue.  As petitioner argues, no allowance has been                    
               made for business expenses that would be normal under                  
               such circumstances.  However, despite petitioner’s                     
               claims of uncertainty, amounts determined to be her                    
               income are specified in the notices of deficiency sent                 
               to her for the years in issue as attributable to                       
               reporting by third-party payors.  In any event, it                     
               appears that the within cases contain common issues.                   
               Upon due consideration and for cause, it is hereby                     







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011