Crop Associates-1986, Frederick H. Behrens, Tax Matters Partner - Page 7




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               On August 11, 1992, respondent and the petitioning partners            
          jointly moved for a continuance, which was granted on August 13,            
          1992.                                                                       
               On January 12, 1994, we again set this case for trial at the           
          trial session scheduled to commence in Washington, D.C., on                 
          October 31, 1994.                                                           
               On July 22, 1994, the petitioning partners moved for                   
          sanctions on account of alleged discovery abuses and violations             
          by respondent (the motion for sanctions).  Respondent objected to           
          the motion for sanctions.  The petitioning partners replied to              
          that objection, alleging additional incidents of misconduct.  The           
          petitioning partners alleged the following incidents of                     
          misconduct by respondent:                                                   
               (1) Destruction of documents potentially                               
                    discoverable by petitioners.                                      
               (2) Failure to comply with certain discovery                           
                    orders of the Court.                                              
               (3) General failure to provide timely, accurate,                       
                    and complete discovery.                                           
               (4) Breaches of grand jury secrecy.                                    
               (5) Bad-faith withholding of pre-grand jury                            
                    documents.                                                        
          We considered each of the petitioning partners’ claims, and we              
          denied the motion for sanctions in its entirety.                            
               On October 12, 1994, the petitioning partners again moved              
          for dismissal or alternative relief based upon alleged violations           






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