- 16 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011