Richard L. Clark - Page 3

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               Petitioner failed to file Federal income tax returns for               
          2001 and 2002.  Petitioner did not submit to respondent’s agents            
          or counsel, to the Court during trial, or during an opportunity             
          provided after trial, the amounts of or evidence of deductions              
          and exemptions to which he claimed entitlement.  Records may have           
          been lost during a fire at petitioner’s father’s residence in               
          2005, but petitioner made no attempt to reconstruct records or              
          obtain corroboration of his claims.                                         
               The above findings of fact are very sketchy because the                
          parties in this case failed to stipulate or otherwise to provide            
          a satisfactory record.  Petitioner was poorly advised, apparently           
          by a person not admitted to practice before the Tax Court.                  
          Petitioner did not cooperate with respondent in preparing the               
          case for trial, which led to excessive reactions by respondent,             
          including excessive interrogatories and motions.  Respondent’s              
          interrogatories contained eight pages of “definitions” and                  
          “instructions” and were, in effect, directions to require                   
          petitioner to lay out his case in writing rather than simple                
          questions such as those anticipated by Rule 71.  See Pleier v.              
          Commissioner, 92 T.C. 499 (1989).  Such interrogatories are                 
          particularly inappropriate against a pro se petitioner and were             
          unnecessary in this case because petitioner’s compliance with               
          other Rules and the standing pretrial order would have supplied             

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