The appellants appeal the order of the Tax Court dismissing their petition for a redetermination of tax liability. The Tax Court dismissed the petition for failure to comply with the court's order compelling discovery, pursuant to Tax Court Rule 104(c), 26 U.S.C. foll. § 7453 (hereinafter T.C.R. 104(c)). We hold that the limitations imposed on the discretion of the district courts to dismiss a...
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