Mildred I. Criss, et al. - Page 13




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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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