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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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