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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.
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