Jan McMaster - Page 9

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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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