Willis Clark - Page 3




                                        - 3 -                                         
          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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