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At the time petitioner filed the petition in this case, he
resided in East Sussex, England.
On November 25, 1997, respondent mailed to petitioner a
notice of deficiency (November 25, 1997 notice) with respect to
his taxable years 1993 and 1994, which he received. On February
9, 1998, petitioner filed a petition in the Court with respect to
the November 25, 1997 notice. (We shall refer to the case that
petitioner commenced on February 9, 1998, with respect to the
November 25, 1997 notice relating to his taxable years 1993 and
1994 as the case at docket No. 2446-98.) The Court set the case
at docket No. 2446-98 for trial on December 14, 1998, in Balti-
more, Maryland. The Court continued the trial in that case until
April 12, 1999, and set the place of that trial in Washington,
D.C.
On April 12, 1999, the Court called the case at docket No.
2446-98 for trial in Washington, D.C. Neither petitioner nor any
authorized representative of petitioner appeared at that trial.
Respondent orally moved to dismiss the case at docket No. 2446-98
for lack of prosecution.
On April 12, 1999, the Court entered an Order of Dismissal
and Decision (April 12, 1999 Order of Dismissal and Decision)
with respect to the case at docket No. 2446-98. In that Order,
the Court (1) granted respondent’s oral motion to dismiss the
case at docket No. 2446-98 for lack of prosecution and
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