Charles J. and Francesca C. Sigerseth - Page 6




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          the Court to compel production of documents and responses to                
          interrogatories.                                                            
               On September 6, 2000, the Court granted respondent’s motions           
          to compel production of documents and responses to                          
          interrogatories, ordering that the production and responses occur           
          on or before September 18, 2000.  The Court warned petitioners              
          that if they failed to comply with the Court’s order, it would              
          impose sanctions under Rule 104, including dismissal of the case            
          or a decision against petitioners.  Petitioners failed to respond           
          to the Court’s order.                                                       
               On September 19, 2000, respondent’s counsel met with Mr.               
          Sigerseth, but petitioners still refused to provide the requested           
          information and documents.  Mr. Sigerseth however provided                  
          respondent’s counsel with a proposed letter to the Court                    
          requesting that petitioners be allowed to withdraw their                    
          petition.                                                                   
               On October 2, 2000, respondent filed a motion to dismiss for           
          failure to prosecute and for a penalty under section 6673.  On              
          October 11, 2000, petitioners responded to respondent’s motion by           
          filing a motion to dismiss for lack of jurisdiction claiming that           
          the notice of deficiency was improper and making protester type             
          arguments.  Petitioners’ motion to dismiss for lack of                      
          jurisdiction was denied.                                                    
               On October 16, 2000, this case was called for trial in San             






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