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more time to build his case and gather necessary information, and
the parties decided to wait until September 26, 2006, to schedule
a meeting.
On September 26, 2006, respondent sent petitioner a letter
detailing the informal discovery process under Rule 91 and
requesting that petitioner send copies of all relevant documents
to respondent pursuant to Branerton Corp. v. Commissioner, 61
T.C. 691 (1974). Respondent also warned petitioner of the
penalty under section 6673(a)(1) for raising frivolous arguments
and instituting proceedings primarily for delay. On the same
day, respondent received a telephone message from petitioner
stating that he did not intend to meet with respondent or provide
any other documentation. Petitioner also informed respondent
that he would not respond to informal discovery requests and that
any further communication would be made only by written
correspondence.
On October 6, 2006, respondent sent petitioner another
letter emphasizing the Court’s requirement to conduct informal
discovery and requesting that petitioner respond to the discovery
requests. Respondent proposed a deadline of October 31, 2006,
for responses to or requests for informal discovery. Respondent
informed petitioner that the Court has characterized arguments
like the ones made by petitioner as frivolous and groundless and
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Last modified: March 27, 2008