Shirley L. Johnson - Page 3




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          petitioners’ counsel, Joe Alfred Izen, Jr. (Izen), under section             
          6673(a)(2)(A).  Unless otherwise indicated, all section                      
          references are to the Internal Revenue Code in effect for the                
          years in issue, and all Rule references are to the Tax Court                 
          Rules of Practice and Procedure.                                             
                                      Background                                       
               The petitions in these cases were filed by Johnson,                     
          individually and as trustee of the NJSJ Trust, on April 5, 1999.             
          In each case, Houston, Texas, was designated by petitioners as               
          the place of trial, although Johnson resided in Indiana at the               
          time.  The cases were first set for trial at a session set for               
          Houston on October 25, 1999.  Izen entered his appearances in                
          these cases on August 4, 1999, and October 18, 1999,                         
          respectively.  Izen is a resident of Texas.                                  
               On or about 75 days before the October 25, 1999, trial date,            
          the last day for serving formal discovery in accordance with Rule            
          70(a)(2), respondent served first sets of interrogatories and                
          requests for production of documents on petitioners.  Thirty days            
          later, on the last day for filing motions to compel discovery,               
          respondent filed motions to compel responses to the first sets of            
          interrogatories and requests for production of documents,                    
          requesting sanctions in the event that petitioners failed to                 
          comply with Court-ordered discovery.  Respondent’s motions to                
          compel discovery were granted.                                               






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