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retain counsel to represent him in this case, petitioner did not
take meaningful steps to obtain counsel or to document any
attempt on his part to obtain counsel, although he had plenty of
opportunities to do so. We conclude from these circumstances
that petitioner’s claim that he intended to retain counsel was
simply another misguided attempt to avoid the reality of his tax
case.
Finally, although petitioner did appear at the calendar call
held on September 7, 2004, during which he argued yet again for a
continuance, the arguments that he made at that time ignored the
multiple warnings that he had received from the Court and
respondent’s counsel to demonstrate his willingness to prepare in
good faith for trial and to abide by the Court’s Rules and
standing pretrial order. Petitioner, who was well aware of the
trial date for his case, also failed to appear for trial. For
all of these reasons, we find 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 at 116-117.
Rule 34(b)(4) requires that a petition in a deficiency
action shall contain “clear and concise assignments of each and
every error” that the taxpayer alleges the Commissioner committed
in the determination of the deficiency and the additions to tax
in dispute. Rule 34(b)(5) requires that the petition contain
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