Patricia R. Carpentier - Page 9

                                        - 9 -                                         
          attempt to cause the removal of Tax Court Judges5 by the                    
          President of the United States.  In an April 10, 2001, Order,               
          petitioner was given until June 11, 2001, to respond or object to           
          respondent’s Supplemental Motion to Dismiss and Motion for                  
          Damages under I.R.C. Section 6673, both filed on April 6, 2001.             
          Petitioner sought and was granted an extension to July 11, 2001,            
          on which date her response was filed.                                       
               Petitioner’s July 11th response advised that she is no                 
          longer seeking, through the office of the President of the United           
          States, to have Tax Court Judges removed.  Petitioner now advises           
          that she would agree to the reduced amounts of income tax                   
          deficiencies sought by respondent.  Petitioner, however, without            
          providing any evidence or reasonable cause for relief, does not             
          agree that she is liable for the reduced additions to tax sought            
          by respondent for petitioner’s failure to file returns and/or pay           
          estimated tax for the taxable years 1989, 1990, 1991, 1992, and             
          1993.  Finally, petitioner contends that no penalty should be               
          awarded under section 6673 because the delay in this case was               
          caused by respondent.                                                       
               In particular, petitioner contends that it was respondent’s            
          refusal to correct the “erroneous Forms 1099" that caused the               
          delay.  In light of the record in this case, we find petitioner’s           
          contentions to be disingenuous.  Petitioner generally failed to             

               5 It is unclear whether petitioner was seeking to remove all           
          the Judges of this Court or only those who were assigned to or              
          acted on petitioner’s case.                                                 

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011