Patricia R. Carpentier - Page 7

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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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