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actions of respondent and the Court. Finally, when required by
the Court to address respondent’s Motion to Dismiss, petitioner
agreed that the Court could enter a decision for the reduced
income tax deficiencies asserted by respondent. Petitioner,
however, did not agree to the additions to tax. In addition,
petitioner contends that a penalty should not be awarded under
section 6673.
Respondent’s motions will be granted.
Background
The following chronology of some of the significant events2
is intended to show the protracted nature of this proceeding and
petitioner’s attempts to delay.
In a petition filed on February 7, 1996, petitioner alleged
respondent’s determination was in error because of “erroneous
1099 income” from a stock brokerage firm. Petitioner made
detailed allegations concerning her former attorney, who was also
attorney for her bank and stock brokerage firm, and others who,
according to petitioner’s contentions, intended to defraud her by
means of some type of conspiracy. Petitioner inherited stock
holdings that she alleged were sold without her knowledge or
financial benefit and she further alleged that Forms 1099 were
2 The chronology set forth in the opinion represents a very
small portion of the filings and proceedings set forth in a
seven-page docket sheet maintained by the Court.
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Last modified: May 25, 2011