- 6 - Pursuant to an order of the Court, respondent filed separate objections to petitioners’ amended motion to dismiss and amended motion to strike on December 19, 2005. On February 27, 2006, the Court held a hearing on petitioners’ amended motions. At the hearing, Floyd Freeman, the revenue agent who examined petitioners’ 2001 and 2002 income tax returns, testified. The Court also received into evidence several exhibits containing material Mr. Freeman considered in his examination of petitioners’ 2001 and 2002 returns. Petitioners did not present evidence at the hearing. On March 1, 2006, petitioners filed a memorandum in support of their amended motion to dismiss for lack of jurisdiction and a motion to shift the burden of proof to respondent. Respondent filed an objection to the motion to shift the burden of proof on April 3, 2006. Pursuant to an order of the Court, petitioners filed a brief in support of their motions on June 23, 2006. With this brief, petitioners filed a request that this Court take judicial notice of the contents of Form 1065, U.S. Return of Partnership Income, and its instructions. After receiving an extension of time, respondent filed an answering brief on August 7, 2006.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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