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MS. HOANG: Your Honor, Dan O’Neill, a paralegal
for the Respondent, has looked at the documents. He
has indicated that Respondent will stipulate to all of
the documents, so the next step will be that Mr.
O’Neill will prepare a draft stipulation of facts, and
hopefully, get it out with all due deliberate speed.
We’re shooting for possibly July 1st, and from then on
we will continue the process.
Moffatt presented several additional documents. After a
brief discussion, Hoang agreed to stipulate these documents as
well.
The Court then advised and prompted as follows:
THE COURT: Okay. So based on that presentation,
there should be no difficulty here in the stipulation.
Mr. Moffatt, I encourage you, pursuant to the Tax Court
rules, to proceed informally now there is counsel in
the case, --
MR. MOFFATT: Yes, sir.
THE COURT: -- and if you want other matters
agreed to or stipulated, to present those documents,
have discussion about them rather than file motions
with the Court because I don’t think you really need
them here.
MR. MOFFATT: I wouldn’t have thought it was
necessary either today, Your Honor.
THE COURT: Okay.
MR. MOFFATT: Thank you very much.
THE COURT: On that basis, Mr. Moffatt, do you
want to withdraw your motion?
MR. MOFFATT: I will do so.
THE COURT: Okay. Well, you can do that orally
right now.
MR. MOFFATT: I’ll do that orally.
THE COURT: As soon as you ask for leave to
withdraw your motion in limine, the Court will permit
the motion to be withdrawn.
MR. MOFFATT: I ask for leave to withdraw the
motion.
THE COURT: Okay. Very good. So it’s withdrawn.
Thank you.
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