Miguel Pagan, Jr. and Martha C. Pagan - Page 6

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          indeed, received this Court's order calendaring for a hearing               
          respondent's motion to dismiss for failure to prosecute.  On July           
          5, 1994, respondent sent petitioners a letter reminding them of             
          the hearing and again requesting the needed substantiation                  
          documents.  Petitioner promised, yet again, to mail the necessary           
          documentation.  No documents were received by the date of the               
          hearing on respondent's motion to dismiss for failure to properly           
          prosecute.                                                                  
          Discussion                                                                  
               In light of the record in this case, the Court finds that              
          petitioners have clearly indicated by their conduct and the                 
          overall record in this case that they no longer wish to contest             
          any issue involved in this case.  Petitioners have the burden of            
          proof as to the deficiencies and additions to tax at issue.                 
               It is well established that this Court can dismiss a case              
          against a party if that party fails to follow our Rules or                  
          otherwise fails to properly prosecute his or her case.  Ducommun            
          v. Commissioner, 732 F.2d 752 (10th Cir. 1983).  Rule 123(b)                
          provides for the dismissal of a case when a taxpayer fails to               
          prosecute his or her case, fails to comply with the Court's Rules           
          or any order of the Court, or for any cause which the Court deems           
          sufficient.  Smith v. Commissioner, 91 T.C. 1049 (1988), affd.              
          926 F.2d 1470 (6th Cir. 1991); Basic Bible Church v. Commis-                
          sioner, 86 T.C. 110, 112 (1986).  Dismissal of a case is a                  






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