- 9 - required by Rule 133,6 which further underscores what appears to be petitioner’s intentional attempt 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 his willingness to prepare his case for trial. Although petitioner stated that he would forward numerous documents to respondent, he never sent anything. In fact, respondent had to send petitioner copies of eight of petitioner’s tax returns to get petitioner to communicate with him at all. Furthermore, petitioner did not appear at the June 13, 2005, trial session or document any legitimate reason for his failure to do so. 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; Smith v. Commissioner, supra. Petitioner’s course of conduct throughout the proceedings demonstrates that these 6Under 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011