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United States a penalty not in excess of $25,000, whenever it
appears to the Court that, among other reasons, the proceedings
have been instituted or maintained primarily for delay. See
Sandvall v. Commissioner, 898 F.2d 455, 459 (5th Cir. 1990),
affg. T.C. Memo. 1989-56; Larsen v. Commissioner, 765 F.2d 939,
941 (9th Cir. 1985). As already described, petitioner has done
little, during the more than 5 years this case has been pending,
to address the merits of her income tax liability. Instead,
petitioner has delayed the proceedings at each step of the way
with spurious attacks on the authority and/or integrity of
respondent’s personnel and the several Judges who have been
involved in this case.
Throughout the proceedings, petitioner and her counsel have
refused and/or failed to comply with respondent’s requests and
this Court’s Rules in connection with the exchange and
stipulation of documents and evidence. Several motions were
filed and addressed under Rule 91(f) in an attempt to cause
petitioner’s compliance with the Court’s Rules.
In an April 24, 2000 Order, the Court explained that, even
though this 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
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