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You won't get another chance to come in and ask for a
continuance." The case was subsequently calendared for trial at
the session scheduled to commence on October 14, 1997, in
Washington, D.C. To date, Mattingly has neither entered an
appearance in this case, nor applied for admission to the Tax
Court bar.
On June 10, 1997, respondent's counsel mailed a letter to
petitioner to ascertain the status of petitioner's trial
preparation for this case. No reply to this letter was received
by respondent. On July 21, 1997, respondent's counsel attempted
to contact petitioner by telephone to inquire about respondent's
still outstanding formal discovery requests. Respondent's
counsel left a message on the telephone answering machine at the
telephone number listed on the petition.
On July 22, 1997, respondent's counsel spoke to petitioner
by telephone, during which conversation petitioner indicated that
he would send a letter to respondent's counsel and the Court
concerning this case. No such letter was received by either
respondent or the Court. On August 21, 1997, respondent's
counsel called petitioner yet again to inquire about respondent's
unanswered formal discovery requests. Respondent's counsel left
a message on the answering machine at the telephone number listed
on the petition.
On August 25, 1997, respondent filed a Motion to Impose
Sanctions under Rule 104(c) (Motion for Sanctions) for
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