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made fewer than 30 days before scheduled trial session dates,4
further underscore what appears to have been an intentional
attempt on the part of petitioner to unreasonably delay the
proceedings. See Williams v. Commissioner, 119 T.C. 276, 279-280
(2002).
Petitioner was repeatedly warned by respondent’s counsel and
by the Court of the consequences of failing to prepare for trial
and of failing to appear at trial. Despite those warnings,
petitioner repeatedly failed to make any reasonable effort to
demonstrate his good faith and willingness to prepare his case
for trial. Although petitioner asserted that he was in the
process of having his returns prepared, he did not take
meaningful steps to meet with his preparer or with respondent,
although he had plenty of time and opportunity to do so. We
conclude from these circumstances that petitioner’s claim that he
intended to prepare and file his returns was simply another
misguided attempt to procrastinate and delay.
We conclude, therefore, that petitioner has failed to comply
with the Court’s Rules and orders and has failed properly to
prosecute this case. See Rollercade, Inc. v. Commissioner, supra
4Under Rule 133, a motion for continuance filed 30 days or
less before the trial date will be denied unless the ground for
continuance arose within that period or there was good reason for
not making the motion sooner. Petitioner requested additional
time to file long overdue tax returns, the absence of which
petitioner admits is a result of his own procrastination.
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