Patricia R. Carpentier - Page 13

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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