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6673(a).” Petitioner’s response to respondent’s summary judgment
motion was to collaterally attack respondent and the Court and to
allege that petitioner was not being afforded Constitutional due
process and/or equal protection under the laws.
In a memorandum opinion (T.C. Memo. 2000-258) the Court
granted partial summary judgment for respondent. The effect of
the Court’s opinion was to preclude petitioner “from contesting
the matters set forth in respondent’s Second Request for
Admissions and respondent’s Amendment to Answer.” The admissions
and the amended answer concerned petitioner’s dividend, interest,
and rental income.3 The opinion also held that “respondent is
not entitled to full summary judgment insofar as material issues
of fact remain in dispute with respect to petitioner’s
entitlement to various deductions for the years in issue.”
Carpentier v. Commissioner, T.C. Memo. 2000-258.
The case was then set on the Portland, Oregon, trial session
beginning on February 12, 2001. On September 15, 2000,
petitioner moved for reconsideration of the above-referenced
holding. Petitioner’s reasons for reconsideration generally
concerned petitioner’s and her counsel’s failure and/or inability
to obtain records and their belief that the Court had a bias and
3 It is noted that because of the changes of the trial
cities and continuances, at least three different Judges have
been involved in petitioner’s case.
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Last modified: May 25, 2011