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petition: “Petitioner hereby gives Notice of WITHDRAWAL of the
petition for review by the United States Tax Court. This Notice
of Withdrawal of petition makes moot, voids, and cancels all
proceedings previously scheduled by this Court for action upon
the petition filed in error.”
Trial Session
This case was set for trial at the Court’s trial session
commencing December 3, 2001, in Houston, Texas (the trial
session).
On Friday, November 30, 2001, an employee of the Court
Clerk’s Office contacted Dr. Trowbridge and reminded him that
petitioners were expected to appear on the following Monday
at the call of the calendar at the trial session. When, on
December 3, 2001, the case was called from the calendar,
petitioners failed to appear. Counsel for respondent appeared
and announced ready for trial. The Court set the case for trial
on the following day (December 4).
When the case was recalled from the calendar for trial on
December 4, 2001, petitioners failed to appear. Counsel for
respondent appeared and announced ready for trial. The deputy
trial clerk reported that he had left two messages for Dr.
Trowbridge at his office regarding the date and time of the
trial. Counsel for respondent orally moved for default judgment
with respect to the initial deficiencies in tax determined
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