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offer to carry the box back to petitioner’s car, petitioner then
incurred great pain and aggravation returning to his car with the
box. We do not believe that this vignette requires us to
sanction respondent’s counsel.
Finally, petitioner characterizes respondent’s actions as
demonstrating obstructionism, vindictiveness, and general bad
faith. Considering respondent’s motion to dismiss for lack of
jurisdiction on the grounds of an untimely filed petition,
subsequently denied, respondent’s motion to dismiss for lack of
prosecution upon petitioner’s failure to appear at the original
call of this case on March 6, 1997, and the aforementioned
problems with discovery and the “Branerton” conference,
petitioner characterizes himself as a victim due to his penury
and physical and mental impairments, and, as such, prays that the
case be dismissed. Each of the incidents of which petitioner
complains was not by itself irregular, and they have only become
heightened in combination by reason of petitioner’s particular
situation. We do not ascribe any vindictiveness or bad faith to
respondent’s individual actions, which had, at each time, some
justification. Accordingly, we find no grounds to grant
petitioner’s motion, and it shall be denied.
We now turn to the merits of this case. Section 162 allows
deductions for all the ordinary and necessary expenses paid or
incurred during the taxable year in carrying on any trade or
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