Anthony D. Long - Page 9

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          Court’s order, and he has yet to produce any documents relevant             
          to his case.  In addition, petitioner failed to appear at the               
          scheduled trial session.                                                    
               Petitioner’s course of conduct throughout the proceedings              
          demonstrates that these failures are due to petitioner’s                    
          willfulness, bad faith, or fault, and we conclude that dismissal            
          of this case is appropriate.6  Petitioner has failed to comply              
          with the Court’s Rules and orders and has failed properly to                
          prosecute this case.  See Rollercade, Inc. v. Commissioner, supra           
          at 116-117; Smith v. Commissioner, supra.  Accordingly, we shall            
          grant respondent’s motion to dismiss this case for lack of                  

                                                       An appropriate order           
                                                  of dismissal and decision           
                                                  will be entered.                    

               6Petitioner has not raised any issue upon which respondent             
          has the burden of proof.  See Rule 142(a); Welch v. Helvering,              
          290 U.S. 111, 115 (1933).  Because petitioner failed to cooperate           
          with respondent’s request for information and documents, the                
          burden of proof does not shift to respondent.  See sec. 7491(a).            

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