Patricia R. Carpentier - Page 5

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          improperly issued to her.  Petitioner also alleged that these               
          same individuals caused or advised her not to file returns in the           
          expectation that she would die “before the truth came out” about            
          the conspiracy to defraud her.  Respondent, in his answer,                  
          generally denied petitioner’s allegations.                                  
               During the pendency of this case, petitioner changed                   
          attorneys several times and on several occasions requested that             
          the location for trial be changed.  The Court attempted to                  
          accommodate petitioner’s needs, and this case was set for trial             
          on various dates and locations, including October 28, 1996, in              
          Washington, D.C.; April 7, 1997, in Los Angeles; May 21, 1998, in           
          Portland, Oregon; September 21, 1998, in Portland, Oregon; and              
          February 12, 2001, in Portland, Oregon.                                     
               Although petitioner sought to continue her case on several             
          occasions, she did not address the underlying merits of                     
          respondent’s determination.  Instead, respondent was forced to              
          resort to the Court’s Rules to promote pre-trial development by             
          means of admissions under Rule 90 and enforced stipulation of               
          facts under Rule 91(f).  In each instance petitioner did not                
          respond to respondent’s requests for admissions or stipulation              
          and/or the Court’s orders to comply.                                        
               Throughout the history of this case petitioner failed to               
          cooperate and/or to communicate with respondent and provide any             
          information.  Instead, petitioner generally accused respondent,             

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