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Discussion
The Court may dismiss a case at any time and enter a
decision against the taxpayer for failure properly to prosecute
his case, failure to comply with the Rules of the Court or any
order of the Court, or for any cause that the Court deems
sufficient. Rule 123(b). Dismissal is appropriate where the
taxpayer’s failure to comply with the Court’s Rules and orders is
due to willfulness, bad faith, or fault. See Dusha v.
Commissioner, 82 T.C. 592, 599 (1984). In addition, the Court
may dismiss a case for lack of prosecution if the taxpayer
inexcusably fails to appear at trial and does not otherwise
participate in the resolution of his claim. Rule 149(a);
Rollercade, Inc. v. Commissioner, 97 T.C. 113, 116-117 (1991);
Smith v. Commissioner, T.C. Memo. 2003-266, affd. sub nom. Hook
v. Commissioner, 103 Fed. Appx. 661 (10th Cir. 2004).
Petitioner has disregarded the Court’s Rules and standing
pretrial order by failing to cooperate meaningfully with
respondent to prepare this case for trial. Petitioner’s pattern
of procrastination and inaction made it impossible for the
parties to exchange information, conduct negotiations, or prepare
a stipulation of facts before trial. Petitioner’s several
requests for more time to file his delinquent returns, which were
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