- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011