Patricia R. Carpentier - Page 4

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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.                                  
               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