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Petitioner has disregarded the Court’s Rules and standing
pretrial order by failing to cooperate meaningfully with
respondent to prepare this case for trial. Petitioner’s pattern
of canceling scheduled conferences, providing notice of his
intent not to attend shortly before each conference was to take
place, and ignoring respondent’s requests for production of
records made it impossible for the parties to exchange
information, conduct negotiations, or prepare a stipulation of
facts before trial. Petitioner also failed to prepare and submit
a pretrial memorandum before either of the scheduled trial
sessions, and he still has not produced all of the documents
relevant to his case. Petitioner intentionally attempted to
delay the proceedings by filing a motion for continuance before
the September 7, 2004, trial session. See Williams v.
Commissioner, 119 T.C. 276, 279-280 (2002). Petitioner’s motion
for continuance was filed less than 30 days before trial and
failed to verify the existence of any exceptional circumstances
that justified postponing the trial. See Rule 133. Moreover,
petitioner failed to appear at the September 7, 2004, calendar
call. Despite respondent’s attempts to contact petitioner about
the September 9, 2004, hearing and respondent’s warning that the
Court might dismiss the case if petitioner failed to attend,
petitioner did not appear at the hearing on September 9, 2004, or
provide proof of any legitimate reason for his failure to do so.
Petitioner’s allegations that he was unable to communicate
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