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On August 22, 1994, respondent sent a Branerton letter,
Branerton Corp. v. Commissioner, 61 T.C. 691 (1974), to peti-
tioner, in which respondent invited petitioner to a conference at
respondent's San Jose, California, office. In the letter,
respondent also suggested that petitioner assemble all documenta-
tion which she planned to use to support her case in trial.
Respondent also sent the same Branerton letter, Branerton Corp.
v. Commissioner, supra, to petitioner Dennis P. Raquet, except
that respondent requested a conference with him on a different
date.
Petitioner Dennis P. Raquet did subsequently meet with
respondent. Petitioner Diana C. Raquet, however, failed to
attend the conference and never furnished respondent with the
requested documentation.
By means of a notice setting case for trial, served upon
petitioners, petitioners were informed that this case was
calendared for trial in Los Angeles, California, with a time and
date certain. This notice included the following paragraphs:
The calendar for that Session will be called at
10:00 A.M. on that date and both parties are expected
to be present at that time and be prepared to try the
case. YOUR FAILURE TO APPEAR MAY RESULT IN DISMISSAL
OF THE CASE AND ENTRY OF DECISION AGAINST YOU.
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