United States Tax Court
Loretta H. and Steve L. C. ) Docket No. 152xxx
Petitioners )
)
Vs ) Motion to Show Cause why the Proposed Facts in Evidence
) Should not be Accepted as Established.
Commissioner of Internal Revenue )
Respondent )
The Petitioners move, pursuant to the provisions of Tax Court Rule 91 (f), that the Court issue an Order to Show Cause requiring the Respondent at the earliest practical time, to show cause why the facts and evidence set forth in the attached copy of the Petitioners’ proposed Stipulations of Facts, marked Exhibit A, should not be accepted as established for the purposes of this case.
1. The Petitioner has set forth in Exhibit A, attached hereto, a proposed Stipulation of Facts, in accordance with the requirements of tax Court Rule 91(f).
2. Petitioners need answers or an agreement to these stipulations to prepare and present a case. The information sought is known to the Commissioner and no legitimate reason exists for them not to stipulate.
3. WHEREFORE, Petitioners request:
A. That this motion be granted and that the Court order the Respondent to show cause why the facts and evidence covered by this motion, set forth in Exhibit A attached hereto, should not be accepted as established for the purpose of this case in accordance with Tax Court Rule 91 (f).
CERTIFICATE OF SERVICE: I hereby certify that on or about this date, I mailed properly a copy of this pleading to the Respondent at his or her proper mail addresses.
________________________ DATE: January 25, 2008 Steve L. C. Piedmont, SC 29673
________________________ DATE: January 25, 2008 Loretta H. C. Piedmont, SC 29673
United States Tax Court
Loretta H. and Steve L. C. ) Docket No. 152xxx
Petitioners )
)
Vs ) Stipulation of Facts by Petitioner
)
Commissioner of Internal Revenue )
Respondent )
It is hereby stipulated that, for the purpose of this case, the following statements may be accepted as facts and all exhibits referred to herein and attached hereto may be accepted as authentic and are incorporated in this stipulation and made a part hereof; provided, however, that either party has the right to object to the admission of any such facts and exhibits in evidence on the grounds of relevancy and materiality, but not on other grounds unless expressly reserved herein, and provided, further, that either party may introduce other and further evidence not inconsistent with the facts herein stipulated.
_______________________________ ___________________________________
Loretta & Steve S. Steven Webster, Senior Attorney
Greenville, SC Tax Court Bar No. WS0410
Federal Place
Exhibit A