- 3 - (4) she should have relieved petitioner of failure-to-pay penalties for the years in issue. At trial petitioner’s testimony was brief, dealing mostly with a decline in the value of her stock portfolio. She called no witnesses, and she offered one document, which, because of respondent’s relevance objection, we did not receive into evidence. Respondent did not question petitioner, and he called no witnesses of his own. We set a briefing schedule, requiring seriatim briefs, with respondent to go first. We explained to petitioner that, in her brief, she would be able to respond to respondent’s brief and to raise any additional arguments she wished to raise. Petitioner agreed that she was satisfied to proceed that way. Respondent filed an opening brief of 21 pages, requesting 34 proposed findings of fact and addressing petitioner’s claims as summarized by the Court at trial. Petitioner filed an answering brief of one page (plus cover sheet), in which she describes her loss of employment in 1997 and the challenge, since that time, of living on savings in a declining securities market. She states that, in the spring of 2006, she took a large distribution from her retirement account to pay down her credit card debt of over $120,000. She further states that, in the spring of this year, she took another large distribution in order to rebuild an investment portfolio and to prepare for upcoming expenses, including exploring employment and business opportunities and a possible home purchase.Page: Previous 1 2 3 4 5 NextLast modified: November 10, 2007