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interrogatories. In the respective September 19, 2001 Orders in
the cases at docket Nos. 10765-00 and 10766-00, the Court further
ordered respondent to file written reports in those respective
cases on or before October 9, 2001, informing the Court whether
petitioners in those cases had complied with the Court’s
respective September 19, 2001 Orders. The Court’s respective
September 19, 2001 Orders put petitioners on notice in the cases
at docket Nos. 10765-00 and 10766-00 that if they did
not fully comply with the provisions of this Order,
this Court will be inclined to impose sanctions pursu-
ant to Tax Court Rule 104, which may include dismissal
of this case and entry of a decision against petition-
ers.
On September 14, 2001, respondent filed a motion to consoli-
date the instant cases for trial, briefing, and opinion, which
the Court granted on September 24, 2001.
On October 2, 2001, petitioners in these cases filed a
motion to continue the trial (petitioners’ motion to continue)
“until such time as the Petitioner has time to answer th [sic]
Respondent’s Motion to Compel Responses to Respondent’s Interrog-
atories.” In support of that motion, petitioners alleged that
“Petitioner is not [in] receipt of any of the interrogatories
that the Respondent wishes answered in a timely manner. They
were apparently sent to the attorney of record who was fired.”
The reason quoted above for petitioners’ asking the Court to
grant petitioners’ motion to continue was false and groundless.
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