Anthony D. Long - Page 8

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          his case, failure to comply with the Rules of the Court or any              
          order of the Court, or for any cause that the Court deems                   
          sufficient.  Rule 123(b).  Dismissal is appropriate where the               
          taxpayer’s failure to comply with the Court’s Rules and orders is           
          due to willfulness, bad faith, or fault.  See Dusha v.                      
          Commissioner, 82 T.C. 592, 599 (1984).  In addition, the Court              
          may dismiss a case for lack of prosecution if the taxpayer                  
          inexcusably fails to appear at trial and does not otherwise                 
          participate in the resolution of his claim.  Rule 149(a);                   
          Rollercade, Inc. v.  Commissioner, 97 T.C. 113, 116-117 (1991);             
          Smith v. Commissioner, T.C. Memo. 2003-266, affd. sub nom. Hook             
          v. Commissioner, 103 Fed. Appx. 661 (10th Cir. 2004).                       
               Petitioner disregarded the Court’s Rules and standing                  
          pretrial order by failing to cooperate with respondent in                   
          preparing his case for trial.  Respondent’s counsel repeatedly              
          asked petitioner to comply with respondent’s informal discovery             
          requests and to cooperate in preparing a stipulation of facts.              
          Despite those requests, petitioner failed to respond to or                  
          produce any documents supporting his position.  Petitioner’s                
          continuous refusal to meet respondent’s requests for discovery              
          made it impossible for the parties to exchange information,                 
          conduct negotiations, or prepare a stipulation of facts before              
          trial.  Petitioner failed to prepare and submit a pretrial                  
          memorandum before the scheduled trial session as required by the            

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