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disclosing the requested information. Petitioner has completely
failed to establish its entitlement to tax-exempt status.
We also note that petitioner has failed to prosecute its
case properly.1 Petitioner failed to file a brief, as ordered by
the 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 Larry D.
Bowen Family Found. v. Commissioner, T.C. Memo. 1999-149, wherein
we reached the same result based on an administrative record that
was virtually identical to the administrative record at hand; as
1 Petitioner's representative, Mr. Tully, is no stranger to
litigation. 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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