James H. K. Wong - Page 3




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          Control Number”.  This Court and other courts have encountered              
          these and similar arguments repeatedly and we have repeatedly               
          rejected these arguments as frivolous.  See, e.g., Rowlee v.                
          Commissioner, 80 T.C. 1111 (1983); Crow v. Commissioner, T.C.               
          Memo. 1995-584, affd. per curiam 92 F.3d 1177 (4th Cir. 1996);              
          Allnutt v. Commissioner, T.C. Memo. 1991-6, affd. per curiam 956            
          F.2d 1162 (4th Cir. 1992); Sterner v. Commissioner, T.C. Memo.              
          1989-352; Kearse v. Commissioner, T.C. Memo. 1988-249, affd. per            
          curiam 883 F.2d 69 (4th Cir. 1989).  The Court, therefore, on its           
          own motion, grants summary judgment with respect to these issues            
          and sustains respondent’s determinations.                                   
               In many of the cases cited above we awarded penalties under            
          section 6673.  Section 6673(a) provides that, if the Court                  
          determines that proceedings are maintained by a taxpayer                    
          primarily for delay or the position of a taxpayer is groundless             
          or frivolous, the Court may award penalties to the United States            
          in an amount not in excess of $25,000.  At the hearing,                     
          petitioner acknowledged that he was aware that we have repeatedly           
          rejected his arguments and have imposed penalties in similar                
          cases.                                                                      













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