John M. Schaefer - Page 13

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          revealed no evidence to suggest laceration, contusion, or                   
          abrasion.  We are not convinced that petitioner could not                   
          assemble his records because of the assaults.                               
               Petitioner also contends that we should have granted his               
          second motion for continuance because he hired an accountant 2              
          weeks before the Reno session to assist him in preparing for                
          trial.  Employment of an attorney shortly before trial ordinarily           
          is not grounds for a continuance, Rule 134; see Dorsch v.                   
          Commissioner, T.C. Memo. 1992-384, affd. 4 F.3d 996 (7th Cir.               
          1993); likewise, belated hiring of an accountant ordinarily is              
          not grounds for a continuance, see Harris v. Commissioner, T.C.             
          Memo. 1992-638.                                                             
               Petitioner objects to the fact that we held the trial in               
          Reno.  This argument surprises us because petitioner joined in              
          the motion to continue this case and change the place of trial to           
          Reno.                                                                       
               It is within our discretion to consider the prejudice to all           
          parties to a case and to the Court when ruling on a motion to               
          continue a trial.  See Morris v. Slappy, 461 U.S. 1, 11-12 (1983)           
          (trial court granted broad discretion on matters of continuance);           
          Ungar v. Sarafite, 376 U.S. 575, 589 (1964); Brooks v.                      











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