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any petitions or documents in accordance with the tax
year 2002. (Docket 5557-05).
I do not understand how you can consolidate my cases,
when one case is not in existence. I request this
court correct its records so I may prepare my case for
trial.
The Court responded to petitioner’s letter, enclosing a copy of
the petition that she had filed in docket No. 5557-05, contesting
the statutory notice for 2002. The Court’s letter, dated
July 27, 2006, continued:
Respondent’s status report was filed July 13,
2006, in response to the Court’s Order dated June 6,
2006. Based on respondent’s report, the attachments,
and your letter, it is obvious that you have not
complied with the Court’s Order. Notwithstanding your
“busy schedule”, immediate attention to these pending
matters is necessary. If you do not comply with the
applicable statutes and the Court’s Orders and Rules
with respect to the exchange of documents and
substantiation of your claimed deductions, none may be
allowed at the time of trial.
Moreover, your communications to date suggest that
these proceedings may have been instituted or
maintained primarily for delay and that you have
unreasonably failed to pursue available administrative
remedies. In such circumstances, Internal Revenue Code
section 6673 authorizes a penalty not in excess of
$25,000 (in each docketed case). Therefore, you are
urged to give these matters your immediate, thorough
and appropriate attention.
On September 5, 2006, petitioner filed a motion for
continuance. Respondent objected to petitioner’s motion for
continuance because, in part:
2. Petitioner alleges in her Motion for
Continuance that more time is needed to secure records,
prepare for trial, and fill out stipulations.
Respondent issued notices of deficiency to petitioner
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