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3. Discussion
Petitioner failed to file income tax returns for 11 years
and offers no justification for that failure. She instituted a
proceeding in this Court without assigning any error to
respondent’s determinations. When she finally did state her
position in her amended petition, she relied on few averments of
fact and relied principally on Constitutional and procedural
arguments, which she later abandoned or was unable to prove. She
made Constitutional arguments that we described as groundless.
She failed to cooperate with respondent in preparing this case
for trial. She failed to stipulate to any facts. She instituted
proceedings in the bankruptcy court that were intended only to
shift the forum of her dispute with respondent and could
accomplish little other than to delay a resolution of the issues
in this case. The bankruptcy court described her contentions as
being “without merit”. She has twice brought motions on grounds
rejected by this Court. She has produced nothing to justify her
total rejection of all adjustments made by respondent.
4. Conclusion
We are firmly convinced that petitioner both instituted and
maintained these proceedings primarily for delay. Also, she has
made groundless arguments. She has caused both the Court and
respondent to expend scarce resources to respond to her many
filings and other actions and to conduct a trial at which she
presented evidence that barely touched on even a few of the
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