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OPINION
A Stipulation of Settled Issues, in which respondent agreed
to many of petitioner’s Schedule C deductions, was followed by a
continuance of trial in this case and approximately 17 months of
unproductive discovery skirmishes. When respondent declined to
concede any additional deductions, and shortly before trial,
petitioner sent to the Court a document entitled “Notice of
Non-Suit and Withdrawal of Petition”, which was filed as
Petitioner’s Motion to Dismiss and denied. Once petitioner has
invoked the jurisdiction of this Court, petitioner may not
withdraw or voluntarily dismiss his petition without a decision
being entered against him. See sec. 7459(d); Estate of Ming v.
Commissioner, 62 T.C. 519, 524 (1974). Although petitioner
attempts to portray himself as a victim of unreasonable action by
respondent, our observation of petitioner during trial and our
review of the record in this case convince us that petitioner’s
abusive practices and meritless claims are the cause of his
difficulties.
We need not accept uncontroverted testimony at face value if
it is improbable, unreasonable, or questionable, see, e.g.,
Lovell & Hart, Inc. v. Commissioner, 456 F.2d 145, 148 (6th Cir.
1972), affg. T.C. Memo. 1970-335, or if the totality of the
evidence conveys a different impression. See Diamond Bros. Co.
v. Commissioner, 322 F.2d 725, 731 (3d Cir. 1963), affg. T.C.
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