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On March 2, 2007, respondent filed the motion for entry of
decision. We ordered petitioner to file a response on or before
March 30, 2007. To date, petitioner has not submitted any
response to the Court.
On or about March 15, 2007, petitioner mailed to respondent
a document titled “Limited Opposition to Motion To Confirm
Decision; Declaration of Jackson Behar in Support Thereof”
(limited opposition), but he did not file the limited opposition
with this Court.6 On March 27, 2007, respondent filed a
supplement to his motion for entry of decision and included
petitioner’s limited opposition as an exhibit. In his limited
opposition, petitioner objects to respondent’s failure to include
Great American’s tentative section 179 expense deduction in
calculating Great American’s 2002 profit/loss and asserts that
respondent’s failure adversely affects the calculation of
petitioner’s income tax deficiency for 2002. However, petitioner
does not dispute that he entered into the stipulation or that the
stipulation reflects the settlement reached by the parties.
Neither party has requested an evidentiary hearing on
respondent’s motion, and we conclude that a hearing is not
necessary to decide respondent’s motion.
6The limited opposition was filed in the names of both
petitioner and Don Ticinovich, another partner of Great American,
but only lists petitioner’s docket number.
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