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400, 404 (1980); Branerton Corp. v. Commissioner, 61 T.C. 691,
692 (1974). Although given ample opportunity to comply with our
rules and an order of this Court, petitioner has not done so, and
we descry no valid reason in the record to explain his
noncompliance. He has essentially ignored and defied our order
of April 9, 1997, and by such action, has shown unremitting
disrespect for our rules and an order of this Court.
What we are confronted with here is not an isolated instance
of noncompliance but a pattern of deliberate dilatory behavior.
See Mutual Fed. Sav. & Loan Association v. Richards & Associates,
supra at 93. In that connection we note that from the start
petitioner failed to cooperate with respondent's informal
discovery, the "bedrock" of practice before this Court.
Branerton v. Commissioner, supra at 692. Petitioner then failed,
in violation of Rules 71 and 72, to respond to the formal
discovery requests served by respondent. Finally, petitioner
disregarded the terms of the Court's April 9, 1997, order.
Petitioner's pattern of noncompliance follows on the heels of our
unequivocal warnings that the Court might impose sanctions,
including dismissal, if petitioner failed to cooperate.
Second, we conclude that respondent has suffered substantial
prejudice as a result of petitioner's misconduct insofar as the
information and documents requested were indispensable to the
substantive issue regarding Partnership losses at dispute in this
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