Janet Kline - Page 5

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            involving the deductibility of petitioner's claimed partnership                               
            losses.                                                                                       
                  On June 23, 1995, a notice setting this case for trial on                               
            September 11, 1995, in Baltimore, Maryland, along with a Standing                             
            Pre-Trial Order, were served upon Attorney Driscoll.  The notice                              
            clearly indicated that "YOUR FAILURE TO APPEAR MAY RESULT IN                                  
            DISMISSAL OF THE CASE AND ENTRY OF DECISION AGAINST YOU".  On                                 
            August 18, 1995, approximately 3 weeks before the date set for                                
            trial of this matter, respondent filed a motion for an order to                               
            show cause why judgment should not be entered against petitioner                              
            on the basis of Kline v. Commissioner, T.C. Memo. 1994-397.  By                               
            order dated August 21, 1995, petitioner was ordered to "show                                  
            cause in writing on or before September 6, 1995, why respondent's                             
            * * *  motion should not be granted and a decision entered in                                 
            accordance therewith."  Attorney Driscoll was served with a copy                              
            of this order on August 22, 1995.  No response was filed to the                               
            order to show cause.                                                                          
                  When the case was called for trial on September 11, 1995,                               
            neither petitioner nor Attorney Driscoll appeared or otherwise                                
            communicated with the Court.  Counsel for respondent appeared at                              
            the hearing.                                                                                  
                  In Kline v. Commissioner, supra, the Court considered                                   
            whether petitioner was entitled to relief as an innocent spouse                               
            for the additions to tax determined for the 1982 and 1983 tax                                 
            years.  The additions to tax were attributable to a partnership                               




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