- 5 - 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 partnershipPage: Previous 1 2 3 4 5 6 7 8 9 Next
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