- 10 - properly to prosecute these cases, with decisions entered in the full amounts of deficiencies, additions to tax, and penalties determined in the statutory notices. Such showing shall include (1) a representation that, on or before October 23, 2006, petitioner delivered to respondent’s counsel, or to a designee of respondent’s counsel, all documents identifying or substantiating deductions, exemptions, or credits to which petitioner claims entitlement for tax years 2000, 2001, and 2002 and (2) a report with respect to items remaining in dispute after respondent’s response ordered hereinbelow. Such report shall include copies of all documents relating to the items remaining in dispute, identification of witnesses that petitioner would call at any further trial of these cases, a summary of the testimony of each such witness, and an estimate of the time required for such testimony. It is further ORDERED: That, on or before November 22, 2006, respondent shall advise petitioner in writing with respect to any deductions, exemptions, or credit that respondent will allow for the years in issue based on the material produced to respondent by petitioner no later than October 23, 2006. It is further ORDERED: That, on or before December 11, 2006, respondent shall serve on petitioner and file with the Court a written report as to respondent’s then position as to further proceedings in these cases. The parties are advised that further trial of these cases, if appropriate, may be set in Washington, D.C., as indicated at the hearing on September 11, 2006, or, if the parties agree, may be set in Louisville, Kentucky, during the Trial Session of the Court scheduled to commence there on February 5, 2007. Petitioner failed to comply with the Court order of September 11, 2006. She did not present to respondent any substantiation of expenses claimed. She did provide copies of unsigned Forms 1120S, U.S. Income Tax Return for an S Corporation, for the periods ended December 31, 2000;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