John Erwin Hunter II and Alma Esteban Hunter - Page 6

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          Commissioner, supra.  Further, the failure of a party to plead or           
          otherwise proceed as provided in the Court’s Rules may be grounds           
          for the Court to hold the party in default, either on the motion            
          of another party or on the initiative of the Court.  See Rule               
          123(a); Meeker v. Commissioner, supra; Stearman v. Commissioner,            
          supra; Ward v. Commissioner, T.C. Memo. 2002-147.  The Court also           
          may dismiss a case and enter a decision against a taxpayer for              
          his failure properly to prosecute or to comply with the Rules of            
          this Court.  See Rule 123(b); Meeker v. Commissioner, supra;                
          Stearman v. Commissioner, supra; Ward v. Commissioner, supra.               
               We agree with respondent that petitioners have failed to               
          state a claim upon which relief can be granted.  See Funk v.                
          Commissioner, supra at 216-217; Meeker v. Commissioner, supra;              
          Stearman v. Commissioner, supra.  Although they had ample                   
          opportunities to do so, petitioners have still failed to present            
          the Court with a petition containing clear and concise                      
          assignments of errors that petitioners allege respondent has                
          committed in the determination of the deficiency or the                     
          associated penalty.  Petitioners have likewise failed to include            
          in their petition clear and concise statements of the facts on              
          which petitioners base their assignments of error.  Instead,                
          petitioners have included in their petitions and other filings              
          with the Court virtually incoherent arguments.  The petition                
          neither conforms to this Court’s Rules of Practice and Procedure            





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