- 29 - 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 thePage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011