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years. The deficiencies were based in large part upon
respondent’s determination that petitioner received unreported
income during those years. On September 23, 1999, petitioner
filed a petition with this Court disputing the full amount of the
deficiencies and penalties. Petitioner at that time resided in
Riverside, California.
Respondent then answered the petition and further set forth
specific allegations of fact in support of the fraud penalties.
Petitioner’s subsequent reply denied nearly all of respondent’s
affirmative allegations and maintained that petitioner’s tax
reporting was “full and accurate”.
After close of the pleadings this case was set for trial,
and copies of the Court’s standing pretrial order were served on
the parties. Therein, petitioner and respondent were directed to
begin discussions as soon as practicable, to stipulate facts to
the maximum extent possible, and to submit trial memoranda if a
basis of settlement could not be reached prior to trial. The
pretrial order also warned generally that any unexplained failure
to comply with its provisions could result in sanctions,
including dismissal, and stated specifically that failure to
cooperate in the stipulation process was a potential ground for
such sanctions.
On November 3, 2000, at which time this case was calendared
for trial beginning on March 19, 2001, respondent’s counsel wrote
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