Patricia R. Carpentier - Page 12

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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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