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considering imposing a penalty under section 6673(a).” In spite
of the Court’s warning, petitioner continued her collateral
attack and failed to address the underlying issues. Petitioner’s
incorrigible approach continued throughout the proceeding, even
though she was given numerous opportunities to comply in the form
of continuances, additional time, and the vacating of an order
deeming facts to be established under Rule 91(f). In each
instance, petitioner did not use the additional time to address
the underlying issues in her case.
Under these circumstances, we hold the petitioner has
maintained this proceeding primarily for delay. We therefore
award a penalty to the United States in the amount of $15,000
under section 6673(a).
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011