Laurel Ann Curtis - Page 16

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          which have required consideration and response by the Court.                
          Petitioner’s pretrial motions--her motion to dismiss, her motion            
          for sanctions against respondent for failure to litigate in good            
          faith, and her motion for continuance of trial pending                      
          U.S. District Court decision on petitioner’s motion to quash 90-            
          day deficiency notice--run 24 pages, 59 pages, and 53 pages,                
          respectively.  Her posttrial motion for rule 11 sanctions against           
          respondent runs 26 pages.  Petitioner’s motions repeat many of              
          the same arguments made by her on brief and at trial.  In                   
          addition, they contain new propositions that are equally without            
          merit.  We cannot escape the conclusion that some or all of                 
          petitioner’s actions have been taken to delay the final                     
          resolution of her case.                                                     
               Petitioner’s filings have been both numerous and lengthy.              
          Notwithstanding the lack of merit to her arguments, she has                 
          caused both the Court and respondent to expend scarce resources             
          to respond to those filings and to conduct a trial that barely              
          touched the grounds of respondent’s determinations of                       
          deficiencies.  Although this appears to be petitioner’s first               
          trip to the Tax Court, she is deserving of a significant penalty            
          because of the persistence of her frivolous assault.                        
               Accordingly, respondent’s oral motion for damages will be              
          granted and petitioner will be required to pay to the United                
          States a penalty in the amount of $15,000.                                  
                                                  An appropriate order and            
                                             decision will be entered.                

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Last modified: May 25, 2011