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necessary to meet with him in order to prepare his case for
trial. Petitioner was also advised that he could bring his new
representative with him to the meeting to prepare his case for
trial.
Also on June 15, 1999, petitioner was advised in writing
that respondent might file a motion seeking sanctions under
section 6673 because of his failure to meet and discuss the
issues of his case, his various tactics of delay, and his failure
to comply with the Court's orders regarding Respondent's Request
for Production of Documents and Respondent's Interrogatories to
Petitioner.
On June 16, 1999, petitioner's new representative, Gene
Bridges (Bridges), of Associated Tax Consultants, sent respondent
a letter by facsimile in which petitioner claimed to be a
nonresident alien. This letter was submitted in lieu of
attending a scheduled conference on June 18, 1999.
Discussion
The Tax Court is authorized under section 6673(a)(1) to
require a taxpayer to pay to the United States a penalty not in
excess of $25,000 when it appears to the Court that the
proceedings have been instituted or maintained by the taxpayer
primarily for delay or if the taxpayer's position in the
proceedings is frivolous or groundless. See sec. 6673(a)(1)(A)
and (B). A position maintained by the taxpayer is "frivolous"
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