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He wants to go directly to Tax Court.” On June 22, 2004, Ace
recommended that, because Moffatt “will not sign the decision
documents unless he is awarded attorney fees”, the case be
forwarded to respondent’s counsel’s office for trial preparation.
The Court, having not received any filing from the parties
after the May 17, 2004, hearing described supra, on July 9, 2004,
calendared the case for trial at the December 13, 2004, session
in Los Angeles.
On August 16, 2004, petitioner filed a motion in limine
similar to the one filed on April 5, 2004, described supra. On
August 19, 2004, the Court conducted a telephone conference with
the parties to discuss this motion. The Court’s order dated
August 23, 2004, states that as a result of the conference, the
Court understood respondent intended “to stipulate without
reservation to certain documents that are the subject of the
motion and that are described in the transcript of a hearing in
this case held on May 17, 2004.” The Court concluded that the
stipulation procedure will better serve petitioner’s aims than
the motion, and so denied the motion in limine.
On August 27, 2004, Lorraine Y. Wu (hereinafter sometimes
referred to as Wu) sent to Moffatt a stipulation of facts. In
her cover letter, Wu noted that she would prepare a stipulation
of settled issues, which she would shortly send to Moffatt.
Moffatt responded on August 30, 2004. Moffatt agreed that the
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