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allegations.
Petitioner sent respondent interrogatories, and requests for
admissions and production of documents, all of which were
frivolous (e.g., petitioner is not a “person liable” for tax; he
did not volunteer to file returns or pay tax; respondent’s
employees lacked authority; the substitute for return is
invalid).
On May 7, 1999, respondent’s counsel sent petitioner a
letter stating that petitioner had taken tax protester type
positions which could result in imposition of monetary sanctions.
Respondent’s counsel attached to the letter copies of 11 recent
Tax Court cases in which we rejected arguments similar to those
raised by petitioner. On August 19, 1999, respondent’s counsel
sent another letter to petitioner in which he said that
petitioner had not cooperated in preparing for trial and advised
petitioner that he could be subject to a penalty under section
6673. Respondent’s counsel attached a copy of section 6673 to
the August 19, 1999, letter. Petitioner filed a motion for
summary judgment and a pretrial memorandum in which he made only
frivolous arguments. He did not dispute any of the adjustments
in the notice of deficiency. We denied his motion for summary
judgment.
In respondent’s pretrial memorandum, respondent contended
that petitioner is liable for the section 6673 penalty. At
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