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penalty under section 66621 in the amount of $43,208. After a
concession by respondent,2 the resulting deficiency and accuracy-
related penalty for 1994 are $151,392 and $30,278, respectively.
The sole issue for decision is whether respondent's motion
to dismiss for failure properly to prosecute should be granted.
We hold it should.
At the time the petition in this case was filed, petitioner
resided in Kent, Washington.
Background
This case was originally scheduled for trial in Hartford,
Connecticut, on March 16, 1998. Petitioner twice requested a
continuance from the March 16, 1998, Hartford trial session.
Both requests were denied. By letter dated November 26, 1997,
respondent's counsel in Hartford asked petitioner to provide
documents pertinent to the issues in the case. Petitioner did
not. On January 27, 1998, counsel for respondent sent petitioner
a proposed stipulation of facts. Petitioner did not sign it.
1All section references are to the Internal Revenue Code in
effect for the taxable year in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated.
2Petitioner's residence was sold in 1992, and no replacement
residence was purchased. Respondent concedes that the gain on
the sale of petitioner's residence is not taxable in 1994, the
only year presently before the Court.
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