Carolyn M. Fankhanel - Page 29

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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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