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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).
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