- 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 herebyPage: 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