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requiring the parties to stipulate all facts and exhibits which
should not fairly be in dispute. She refused to stipulate even
her address or marital status until the Court questioned her on
the record, and then she moved to have that stipulation set
aside. She was consistently late in her filings, e.g., missing
Court deadlines by weeks and months.
Petitioner’s dilatory tactics and lack of cooperation cannot
be excused by the fact that she was proceeding pro se. Litigants
are presumed to know the tax laws and the Rules, even when
proceeding pro se. See Faretta v. California, 422 U.S. 806, 835
n.46 (1975).
This factor weighs against petitioner.
7. Engaging in Illegal Activities
Engaging in illegal activities is indicative of fraud.
Bradford v. Commissioner, 796 F.2d 303 (9th Cir. 1986).
Petitioner engaged in illegal activities to defraud
respondent and her other creditors. In fact, she was convicted
of five counts of bankruptcy fraud and one count under section
7201 of willfully attempting to evade and defeat the payment of
$353,394 of Federal income taxes for 1983, 1984, 1986, and 1987.
This factor weighs against petitioner.
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