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          2the Court and required by Rule 151, and it has failed to explain           
          its failure to do so.  We have previously treated such inaction             
          by a party as an abandonment of those issues not addressed.  See            
          Calcutt v. Commissioner, 84 T.C. 716, 721 (1985).  We also have             
          held that the failure to file a brief may justify the dismissal             
          of all issues as to which a taxpayer has the burden of proof.               
          See Stringer v. Commissioner, 84 T.C. 693, 708 (1985), affd.                
          without published opinion 789 F.2d 917 (4th Cir. 1986).                     
               We sustain respondent's determination.  See also Tamaki                
          Found. v. Commissioner, T.C. Memo. 1999-166; Tate Family Found.             
          v. Commissioner, T.C. Memo. 1999-165; Larry D. Bowen Family                 
          Found. v. Commissioner, T.C. Memo. 1999-149, wherein we reached             
          the same result based on administrative records that were                   
          virtually identical to the administrative record at hand; as is             
          true with the case here, Mr. Tully also organized the                       

               1(...continued)                                                        
          litigation.  In addition to the cases cited in the last paragraph           
          of this memorandum opinion, he has filed cases in this Court on             
          at least three prior occasions, see Tully v. Commissioner, an               
          Order of this Court dated Jan. 8, 1998 (dismissing the case for             
          failure to prosecute), vacated and remanded without published               
          opinion 164 F.3d 631 (9th Cir. 1998) (with instructions to                  
          dismiss petition for lack of jurisdiction); Tully v.                        
          Commissioner, T.C. Memo. 1997-310, on appeal (9th Cir., July 29,            
          1997); Oliver Family Found. v. Commissioner, T.C. Memo. 1997-220,           
          he has prosecuted or is prosecuting the appeal of two of these              
          cases before the Court of Appeals for the Ninth Circuit, and he             
          prosecuted one case before a Federal District Court, see Tully v.           
          Kaply, 81 AFTR 2d 98-2125 (C.D. Cal. 1998).                                 






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