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claims against the United States, the Internal Revenue Service
(IRS), and various IRS officials “Because Rayner’s requests are
patently frivolous”. The Court of Appeals for the Fifth Circuit
warned:
Rayner’s appeal surpasses mere frivolity and
registers an extraordinary score on the appellate scale
of vexation. Mr. Rayner is given notice that future
frivolous appeals will be subject to the full panoply
of sanctions authorized by Federal Rules of Appellate
Procedure 38. We encourage the government to consider
moving for such sanctions if faced with frivolous
actions like this one in the future. [Id.]
We conclude that petitioner is liable for a penalty of
$5,000 under section 6673.
Accordingly,
An order will be entered
granting respondent’s motions for
summary judgment and for a penalty, and
decision will be entered for
respondent in amounts consistent
with the foregoing.
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Last modified: May 25, 2011