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filed his answer with the Court. On May 16, 2000, this case was
calendared for the Court’s trial session in San Francisco,
California, beginning on October 16, 2000. On June 12, 2000,
respondent’s Appeals Office contacted petitioners in an attempt
to resolve the disputed issues. There is no evidence in the
record indicating that petitioners responded to the Appeals
Office.
On July 10, 2000, respondent’s counsel wrote petitioners to
obtain informal discovery, prepare a stipulation of facts,
explain the consequences of not appearing at trial, and inform
them of respondent’s anticipated motion to seek a section 6673
penalty. In addition, respondent’s counsel suggested that the
parties meet on July 20, 2000, to address the above matters.
Petitioners did not provide respondent with the requested
information, but, on July 24, 2000, Mr. Sigerseth wrote
respondent to suggest a meeting on September 3, 4, or 5, 2000.
In the correspondence, Mr. Sigerseth stated that “Cal: Avila”
would be petitioners’ counsel and would attend the meeting.
On July 26, 2000, respondent’s counsel stated in a letter to
petitioners that he would be willing to meet on September 5,
2000, with petitioners and Mr. Avila. He informed them, however,
that Mr. Avila could not represent petitioners at the Tax Court
unless he was an attorney (or other person) admitted to practice
before the Tax Court. He reminded petitioners again that
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Last modified: May 25, 2011