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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