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sponse to respondent’s motion to dismiss for lack of prosecution
and to impose sanctions under section 6673 in the case at docket
No. 10766-00.7 Each of those respective responses contained
arguments and contentions that the Court found in an Order dated
January 18, 2002 (January 18, 2002 Order) in the cases at docket
Nos. 10764-00 and 10766-00 to be frivolous and/or groundless. In
the January 18, 2002 Order, the Court reminded each petitioner
about section 6673(a)(1).8
7On Feb. 19, 2002, Richards Charitable Trust filed a re-
sponse to respondent’s motion to hold petitioner in default in
the case at docket No. 10767-00. Although the Court did not
receive and have that response filed until Feb. 19, 2002, it
appears to have been mailed to the Court around Nov. 20, 2001.
Presumably because of the delays in mail delivery that the Court
has been experiencing since mid-October 2001, the Court’s receipt
of that response was delayed.
8Sec. 6673(a)(1) states:
SEC. 6673. SANCTIONS AND COSTS AWARDED BY COURTS.
(a) Tax Court Proceedings.--
(1) Procedures instituted primarily for de-
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
(continued...)
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