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We now address respondent's motions to dismiss in docket Nos.
24986-97 and 24987-97 on the basis of Sloan’s estate’s failure to
properly prosecute. This Court, like every court, has the inherent
power, in the exercise of its discretion, to dismiss a case for
want of prosecution. See, e.g., Link v. Wabash R.R. Co., 370 U.S.
626, 629-632 (1962); Harper v. Commissioner, 99 T.C. 533, 540
(1992) (failure to comply with discovery requests and orders or to
prepare for trial). Rule 123(b) provides in relevant part:
(b) Dismissal: For failure of a
petitioner properly to prosecute or to comply
with these Rules or any order of the Court or
for other cause which the Court deems
sufficient, the Court may dismiss a case at
any time and enter a decision against the
petitioner. The Court may, for similar
reasons, decide against any party any issue as
to which such party has the burden of proof,
and such decision shall be treated as a
dismissal * * *.
Paragraph 4.(b) of the petitions in docket Nos. 24986-97 and
24987-97 states that petitioner does not dispute the assumptions
used by the Commissioner in determining the estate and income tax
deficiencies. (It was not until petitioner's opposition to
respondent's motion to dismiss for failure to properly prosecute
that petitioner first raised the issue that the two notices of
deficiency were arbitrary in connection with the $1,728,362 cash-
on-hand adjustment. See supra note 3.)
Petitioner has the burden of proof in docket Nos. 24986-97 and
24987-97. Pursuant to Rule 149(b), “Failure to produce evidence,
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