J. Thomas and Henrietta A. Hardin - Page 10

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          practicing lawyer who ignored this Court’s Orders and procedures.           
               Petitioners failed to submit a Pretrial Memorandum or appear           
          in person at the Louisville trial session.  Petitioners did not             
          enter into a stipulation or make themselves available to                    
          participate in the stipulation process.  Petitioners have, on               
          several occasions, not provided adequate records to substantiate            
          the claimed deductions, although they have been given several               
          opportunities and over 4 years to do so.  Petitioners ignored               
          many meetings respondent scheduled and frequently failed to give            
          respondent any advance notice of petitioners’ intention to miss             
          the meetings.  Despite petitioners’ consistently and continuously           
          maintaining during the entire 4-year period that they have all              
          the necessary documentation, they have neither established nor              
          substantiated the deductions claimed.                                       
               We find that petitioners failed properly to prosecute this             
          case.  In addition, petitioners have ignored this Court’s Orders            
          and Rules and protracted these proceedings.  Further, petitioners           
          failed to provide the Court an explanation why they failed to               
          comply with this Court’s Rules and our Standing Pretrial Order.             
          Petitioners did not respond to respondent’s Motion to Compel                
          Production of Documents and Impose Sanctions or respondent’s                
          Motion to Dismiss for Lack of Prosecution and to Impose Sanctions           
          under section 6673.  Nor did petitioners appear at the hearing              
          held at the Louisville trial session.  In addition, petitioners             






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