Judith Walther - Page 9

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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 June 9, 2005,            
          order.  On October 13, 2005, the Court extended the time for                
          petitioner to file an amended petition and to pay the filing fee            
          until November 3, 2005.  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           
          of justice, we will deny petitioner’s motion for leave.6  It                

               6 See Rice v. Commissioner, T.C. Memo. 2006-236, 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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