OPINION
WELLS, Judge:
The instant case is before the Court on respondent's motion to dismiss Darren L. Darilek (intervenor) for failure properly to prosecute. Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
Petitioner and intervenor filed a joint tax return for taxable year 2002 and divorced...
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