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section 6662(a) in the amount of $1,752. Neither party requested
a hearing and we conclude that none is necessary to decide
respondent's motion.
References to petitioner are to Sharif M. Battikhi. Unless
otherwise indicated, all section references are to the Internal
Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Background
Petitioners are married and lived in San Diego, California,
when they filed their petition.
In the notice of deficiency, respondent determined that
petitioner received $34,824 in unreported income in 1992. After
concessions, respondent now contends that petitioner received
$28,887.90 in unreported income in 1992.
About 5 months before trial, we served the parties with
notice setting this case for trial at a session in San Diego.
Soon thereafter, respondent asked petitioners to provide
information and invited them to attend a pretrial conference.
Petitioners did not respond to that letter. Respondent also gave
petitioners a copy of their monthly bank statements for 1992 and
a copy of the revenue agent's bank deposits analysis showing how
the agent reconstructed petitioners' income.
Respondent invited petitioners to attend pretrial
conferences three other times. Petitioners did not attend any of
them. Instead, petitioners gave affidavits to respondent to
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