-6- 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 ProcedurePage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011