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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 August 15,
2005, order. On October 19, 2005, the Court extended the time
for petitioner to file an amended petition and to pay the filing
fee until November 10, 2005. On January 12, 2006, the Court
granted a second extension to file an amended petition until
February 9, 2006. Though petitioner 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
of justice, we will deny petitioner’s motion for leave.5 It
5 See Rice v. Commissioner, T.C. Memo. 2006-236 and Walther
v. Commissioner, T.C. Memo. 2006-247, in which the taxpayer’s
filings and failure to comply with the Court’s orders were
similar, resulting in the denial of the taxpayer’s motion for
leave to file a motion to vacate the Court’s order of dismissal
for lack of jurisdiction.
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Last modified: May 25, 2011