motion to compel stipulation

Hi, are you able to research and draft a good response for me to a motion to compel stipulation,tax court rule 91f. Basically I did not sign a stipulation of facts document because the irs attorney that drafted it did not include 7 of my documents (against tax court rule 91a) that are essential to the case saying we can add them later. He also did not note in the stipulation my objection to 2 of his facts.
I would also like to know if I can dispute the correctness of the notice of deficiency in my challenge as to why I should not be compelled to accept the stipulation of facts. The notice of deficiency (NOD) listed all issues as outstanding (no expenses accepted) hence the stipulated facts document completed by the IRS counsel listed all items as disputed; but the last Information document request (IDR) from the irs auditor had only 2 items remaining that we could not agree on. Conduct this research and include as to whether or not I can challenge the correctness of the NOD which would also call into question the items listed on the stipulated facts.

We are challenging a few items on the motion and items that were left off. First attachment below is the first 7 pages of the motion received from Mr. xxxx. The last page is the items (42&43) we objected to as to relevance but Mr. xxxx did not note our objection in the stipulation. 

  1. Item 42- does not appear on Exhibit 4R? Personal contract business reported on return not w2 wages. 4R is for quarterlyreporting of income. 2015 1099 income from consulting does not appear on Exhibit 4R either. Our objection as to relevance was not noted in the stipulation.
  2. Item 43- does not appear on Exhibit 5R? Personal contract business reported on return. 5R is for quarterlyreporting of income. 2016 1099 income from consulting does not appear on Exhibit 5R either. Our objection as to relevance was not noted in the stipulation.

3.Correctness of Notice of Deficiency- Should the 57 items on the stipulation be listed or should the correct number of items be the two remaining items on the December 5, 2019 Information Document Request (IDR) form from the auditor. There is also a prior IDR dated 3/13/2019 with just 7 items listed which was requested by Compliance prior to the issuance of the Notice of Deficiency.

Missing Items

Mr. xxxx on his February 3rd email if we would sign stipulation if he included the faxed items but never included them. Mr. xxxx did not include the following items that were mailed, emailed, faxed to him or in Compliance’s possession per the attached Information Document Request forms from March 13, 2019 to December 6, 2019.

Additions to stipulation needed that are relevant and attached below. Per rule 91a objections can be made by Mr. xxxx but cant be omitted from stipulation:

  1. Northrop Grumman ID for consulting business
  2. Northrop Grumman Work Authorization Forms for consulting business
  3. Time-sheets with email approval from Northrop Grumman management for consulting business
  4. Unsworn affidavit

5.Home Improvement Invoices

  1. Information Document Request form-Old IDR, New IDR, (Last IDR- in separate email)
  2. Bank statement

 Let me know if you have any questions.