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By notice dated May 7, 1997, the Court set the case
for trial on October 14, 1997. When the case was called
for trial on October 14, 1997, respondent and Mr. Hartman
appeared before the Court and represented that they were
going to meet with a revenue agent to review Mr. Hartman's
records. Mr. Hartman represented to the Court that he had
all of his "documentation". In response, the Court
directed as follows: "All right. I'll recall the case on
Thursday [October 16, 1997], and at that point, I expect
everything to be taken care of. If not, we'll be ready to
go to trial."
When the parties appeared before the Court on
October 16, 1997, respondent's attorney advised the Court
that the parties had made progress, but they had not
finished reviewing petitioners' documentation.
Respondent's attorney further represented that they needed
3 or 4 days to complete their review. On the basis of
these representations, the Court continued the case and
directed the parties to file a joint status report in 30
days with the expectation that the case would be resolved
in that period. The Court made the following comment to
Mr. Hartman:
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