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year 1994 and an addition to tax under section 6651(a) in the
amounts of $4,092 and $1,091.99, respectively.
Petitioners’ attorney, Lorenzo W. Tijerina (Mr. Tijerina),
filed a timely petition on their behalf on July 22, 1997,
disputing the entire amount of the deficiency and addition to
tax. At the time of the filing of their petition, petitioners
resided in San Antonio, Texas. Respondent filed an Answer on
August 25, 1997, and the issues were joined at that time.
On November 20, 1997, the Clerk of the Court served the
parties with a notice setting the case for trial on the February
9, 1998, trial session in San Antonio, Texas. The Court’s
Standing Pre-Trial Order was also served at the same time.
The Standing Pre-Trial Order, among other things, required
the parties to: (1) Stipulate all facts to the maximum extent
possible; (2) mark all documents and written evidence; (3)
identify all documents or materials which either party expects to
utilize in the event of trial and exchange said documents 15 days
before the first day of the trial session; (4) prepare a trial
memorandum substantially in the form attached to the order, and
submit it to the Special Trial Judge assigned to the session and
the opposing party not less than 15 days before the first day of
the trial session; and (5) identify all witnesses in the trial
memorandum with a brief summary of the anticipated testimony of
such witnesses. The pre-trial order also provided for
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