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at 5-6). However, a timely motion for leave, without more, is
not necessarily sufficient to persuade the Court to grant such
motion. In deciding what action to take, “We are guided
primarily by whether it would be in the interest of justice to
vacate the prior decision. But, we also recognize that
litigation must end at sometime.” Estate of Egger v.
Commissioner, 92 T.C. 1079, 1083 (1989); Manchester Group v.
Commissioner, T.C. Memo. 1997-576.
Petitioner failed to file an amended petition or to pay the
required filing fee in accordance with the Court’s November 10,
2005, order. On January 19, 2006, the Court extended the time
for petitioner to file an amended petition and to pay the filing
fee until February 9, 2006. Although petitioner eventually paid
the filing fee, she failed to comply with the Court’s orders to
file a proper amended petition. After her case was dismissed for
lack of jurisdiction, petitioner waited until the time for appeal
was about to expire to file her motion for leave.
Petitioner has been afforded several opportunities and
sufficient time to file her amended petition. Petitioner has
repeatedly failed to comply with the Court’s orders, and she has
provided no reasonable excuses for her lack of compliance.
Therefore, in the exercise of our discretion and in the interests
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