- 13 - the cases at docket Nos. 9700-00 and 9702-00 were not the first occasions on which the Court reminded Ms. Criss and Criss Trust about section 6673(a)(1).9 Discussion Criss Trust On December 3, 2001, the Court sua sponte issued the Decem- ber 3, 2001 Show Cause Order regarding the Court’s jurisdiction over the case at docket No. 9702-00. Rule 60 provides in pertinent part: (a) Petitioner: (1) Deficiency or Liability 8(...continued) lay, etc.--Whenever it appears to the Tax Court that-- (A) proceedings before it have been instituted or maintained by the taxpayer primarily for delay, (B) the taxpayer’s position in such proceeding is frivolous or groundless, or (C) the taxpayer unreasonably failed to pursue available administrative remedies, the Tax Court, in its decision, may require the taxpayer to pay to the United States a penalty not in excess of $25,000. 9On Sept. 19, 2001, the Court issued a separate Order in each of the cases at docket Nos. 9700-00 and 9702-00 with respect to the motion filed by each petitioner to compel answers to interrogatories. In each of those two Orders dated Sept. 19, 2001, the Court found that each such motion, including attach- ments thereto, contained contentions, statements, and/or argu- ments that the Court found to be groundless and/or frivolous, and the Court reminded petitioner in each of those cases about sec. 6673(a)(1).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011