Patricia R. Carpentier - Page 6

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          of “abuses, negligence, and IRS failure to [cooperate] as to                
          review of erroneous payor 1099's”.  But petitioner did not take             
          steps to either prepare for trial or to develop facts addressing            
          the merits of the controversy before this Court.  Instead and in            
          an attempt to circumvent the Court’s jurisdiction, petitioner               
          used collateral approaches, including the seeking of                        
          congressional assistance and the assistance of the Taxpayer                 
               Petitioner also sought the recusal of one of the trial                 
          judges alleging a “Conflict of Interest, bias and prejudice and             
          special interest” essentially because the trial judge was                   
          appointed by President William Jefferson Clinton and for numerous           
          other related allegations.                                                  
               Due to petitioner’s failure to cooperate and/or failure to             
          follow this Court’s Rules and procedures, respondent, on February           
          15, 2000, moved for summary judgment based on facts that were               
          deemed admitted under the Court’s Rules.  Petitioner responded              
          after several extensions.  In an April 24, 2000 Order, the Court            
          explained that, even though the case had an extended history,               
          petitioner had not produced any probative evidence regarding the            
          underlying issues.  It was further explained that petitioner’s              
          sole approach was to “attack respondent’s counsel and the Court.”           
          The Court, in the April 24, 2000 Order, advised petitioner “that            
          the Court is considering imposing a penalty under section                   

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Last modified: May 25, 2011