Larry J. and Sherilyn Wadsworth - Page 6

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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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