Patricia R. Carpentier - Page 3

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          respondent’s efforts to develop this case for trial, however,               
          respondent discovered that petitioner had unreported rental                 
          income.  That rental income, together with income from interest             
          and dividends that respondent had determined in the above-                  
          referenced notices of deficiency, results in the following                  
          reduced deficiencies and additions to tax, which respondent                 
          requests we decide are due from petitioner, if we grant                     
          respondent’s motion to dismiss for lack of prosecution:                     
                          Income Tax          Additions to Tax                        
               Year      Deficiencies    Sec. 6651(a)(1)   Sec. 6654                  
               1989      $7,214         $1,491.00           $487.86                   
               1990      2,659          664.75              174.10                    
               1991      5,216          1,304.00            298.10                    
               1992      3,841          960.25              167.10                    
               1993      3,938          984.50              164.99                    
               During the more than 5 years this case has been pending,               
          petitioner, who did not file returns for the periods in question,           
          did very little to show that she was not required to report the             
          proceeds from stock transactions reflected on the Forms 1099.  In           
          addition, petitioner did nothing with respect to respondent’s               
          determination of interest, dividend, and rental income.  Instead,           
          petitioner has mounted attacks on respondent’s and the Court’s              
          authority for the purposes of diversion and delay.  After                   
          respondent was able to develop information regarding the Form               
          1099 items causing a reduction in the income tax deficiencies,              
          petitioner continued to attack the authority, integrity, and                

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