- 14 - trial, petitioners failed to appear. Counsel for respondent appeared and announced ready for trial. The deputy trial clerk reported that he had left messages for both petitioners as to the date and time of the trial. Respondent moved to dismiss for default in both cases and the Court set those motions for a hearing on Friday, December 7, 2001. The Court instructed respondent’s counsel to arrange personal service of the petitioners, to inform them of the hearing. The Court heard one witness in support of respondent’s case. On Friday, December 7, 2001, the cases were recalled from the calendar for a hearing on respondent’s motions to dismiss for default. Petitioners failed to appear. Counsel for respondent appeared and announced ready for the hearing. Internal Revenue Agent Marilyn MacIness testified that she had served each petitioner personally with notice of the hearing. The Court took respondent’s motions to dismiss for default under advisement. OPINION I. Motions To Dismiss for Default Respondent has moved (1) that Dr. Trowbridge be held in default with respect to, and that a decision be entered in respondent’s favor in the full amount of, the deficiencies in tax determined by respondent against Dr. Trowbridge for the years 1991 through 1995 and the additions to tax determined byPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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