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Respondent mailed a notice of deficiency to petitioner on
June 18, 1999. Respondent disallowed the attorney’s and
accounting fees deduction claimed on Schedule A and also
disallowed all of the claimed deductions on Schedule C for BHTC,
on the basis that petitioner failed to establish that he paid or
incurred the expenses, and that the expenses were not ordinary
and necessary to his business. Respondent also determined that
petitioner was liable for the addition to tax under section
6651(a)(1) and the accuracy-related penalty under section
6662(a).
Discussion
A. General
At the time of filing the petition, petitioner filed a
Designation of Place of Trial, designating Tampa, Florida. By
notice dated February 3, 2000, this case was set for trial at a
Tampa, Florida, trial session of this Court scheduled to commence
on April 24, 2000. On March 31, 2000, petitioner filed a Motion
to Continue Trial Generally, which was granted. By notice dated
December 8, 2000, this case was again set for trial at a Tampa,
Florida, trial session scheduled to commence February 26, 2001.
A few days before the February 26, 2001, trial calendar, the
Court held a teleconference with petitioner and respondent.
Petitioner requested that the trial be continued. Petitioner
asserted that he had moved to Las Vegas and was unable to appear
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