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only for good cause shown. Pierce Oil Corp. v. Commissioner, 30
B.T.A. 469, 475 (1934). We see no reason to give petitioner a
rehearing based on his belated desire to be represented by
counsel or on his hope that he might develop evidence that he has
failed to develop or present thus far. Petitioner chose to
appear at trial pro se and was afforded a full opportunity to be
heard and represent himself pursuant to Rule 24(b). Although he
could have secured representation for trial if he had so chosen,
he has no basis to complain that the Court did not compel him to
do so or did not appoint counsel for him.6 See Crane-Johnson Co.
v. Commissioner, 105 F.2d 740 (8th Cir. 1939), affg. 38 B.T.A.
1355 (1938), affd. 311 U.S. 54 (1940). Petitioner has not shown
that his failure to present additional evidence was not due to a
lack of diligence on his own part or that a new trial is
warranted. See Selwyn Operating Corp. v. Commissioner, 11 B.T.A.
593, 594-595 (1928); Strasser v. Commissioner, T.C. Memo. 1986-
579.
Accordingly, we deny petitioner’s request for a new trial.
Decision will be
entered for respondent.
6 Petitioner has no constitutional right to an attorney in
this civil matter. See Riland v. Commissioner, 79 T.C. 185, 207
(1982); Cupp v. Commissioner, 65 T.C. 68, 85-86 (1975), affd.
without published opinion 559 F.2d 1207 (3d Cir. 1977).
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