Dennis P. and Diana C. Raquet - Page 7

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                    Your attention is called to the Court's require-                  
               ment that, if the case cannot be settled on a mutually                 
               satisfactory basis, the parties, before trial, must                    
               agree in writing to all facts and all documents about                  
               which there should be no disagreement.  Therefore, the                 
               parties should contact each other promptly and coop-                   
               erate fully so that the necessary steps can be taken to                
               comply with this requirement.  YOUR FAILURE TO COOP-                   
               ERATE MAY ALSO RESULT IN DISMISSAL OF THE CASE AND                     
               ENTRY OF DECISION AGAINST YOU. * * *                                   
               Within the time in which discovery was allowed, respondent,            
          pursuant to Rule 72, served on petitioners Respondent's Request             
          for Production of Documents.  Petitioners failed to respond to              
          Respondent's Request for Production of Documents and Respondent's           
          Request for Admissions.  Thus, respondent filed with the Court a            
          Motion to Compel Production of Documents.  Based on respondent's            
          Motion to Compel Production of Documents, the Court issued an               
          order granting respondent's Motion to Compel Production of Docu-            
          ments and ordering petitioners to produce within 30 days those              
          documents requested in respondent's Request for Production of               
          Documents.  The order also stated:  "in the event petitioners do            
          not fully comply with the provisions of this order, this Court              
          will be inclined to impose sanctions pursuant to Tax Court Rule             
          104, which may include dismissal of this case and entry of a                
          decision against petitioners."                                              
               After the Court granted respondent's Motion to Compel                  
          Production of Documents, respondent spoke with petitioner and               
          discussed possible ways to settle this case.  Pursuant to this              
          conversation, respondent wrote petitioner a letter in which                 





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