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has the burden of proof, this Court should default him.” Id. at
1408. As stated in Bosurgi:
To hold a trial in a case abandoned by the taxpayer is at
best an indulgence of archaic manners and at worst an insult
to the taxpayers who have a rightful claim on this Court’s
time. * * * Entry of a default judgment is appropriate upon
a determination in the sound judicial discretion of the
Court that the pleadings of the moving party set forth facts
sufficient to support the judgment. [Id.; fn. ref.
omitted.]
See also Smith v. Commissioner, 926 F.2d 1470 (6th Cir. 1991),
affg. 91 T.C. 1049 (1988).
We find that by failing to appear at trial and by violating
the standing pretrial order and numerous discovery orders,
petitioner failed to proceed as provided by our Rules and as
required by this Court. Therefore, we find petitioner in default
as to the issues for which respondent bears the burden of proof.
Nonetheless, since respondent bears the burden of proof with
respect to the increased deficiencies and the burden of
production and/or proof with respect to the additions to tax, we
must determine whether respondent has satisfied these
requirements.
1. Liability for Increased Deficiencies.
Respondent moves to increase the deficiencies for each of
the years in issue. Section 6214(a) provides:
SEC. 6214(a). Jurisdiction as to Increase of
Deficiency, Additional Amounts, or Additions to the Tax.--
Except as provided by section 7463, the Tax Court shall have
jurisdiction to redetermine the correct amount of the
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