From lawyer Larry Becraft, noted for representing clients in income tax 
cases:

 Beaty v. United States, 937 F.2d 288, 293 (6th Cir. 1991): "One final 
note. After entering summary judgment and after a notice of appeal had 
already been filed, the district court granted the IRS's motion to 
supplement the record on appeal with materials never considered by that 
court. The IRS now concedes that doing so was improper. Although the 
materials added to the record on appeal were irrelevant to the 
disposition of the case, we nonetheless mention the matter in order to 
comment on the district court's rationale. In its order, the court 
stated that "[s]ince the action is likely to be appealed, and the 
documents serve to bolster the government's position in this case, this 
motion is hereby GRANTED." This statement exhibits a certain confusion 
regarding the proper role of a judge. A central tenet of our republic — 
a characteristic that separates us from totalitarian regimes throughout 
the world — is that the government and private citizens resolve disputes 
on an equal playing field in the courts. When citizens face the 
government in the federal courts, the job of the judge is to apply the 
law, not to bolster the government's case."





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