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resources. As I mentioned to you on the telephone, if
your claims prove to be frivolous, you should be aware
of I.R.C. section 6673, which provides:
(a)(1) Procedures instituted primarily for
delay, etc.--Whenever it appears to the Tax Court
that–-
(1)(A) proceedings before it have been
instituted or maintained by the taxpayer primarily
for delay,
(1)(B) the taxpayer’s position in such
proceeding is frivolous or groundless, or
(1)(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.
(Emphasis added.) We routinely pursue sanctions under
this section in cases of non-cooperation, and we may do
so in your case as well.
(A copy of that letter was attached to respondent’s pending
motion to dismiss.)
On December 17, 2001, respondent filed a Motion to Show
Cause Why Proposed Facts in Evidence Should not be Accepted as
Established (motion to show cause). Attached to respondent’s
motion to show cause was a proposed stipulation that, among other
things, set forth facts for 1996 and 1997 that included the
following: Petitioner was married to Storks; petitioner and
Storks resided in Arizona; and petitioner was licensed as a
chiropractor by the State of Arizona. Prior to 1996, petitioner
practiced her profession at Canyon State Chiropractic. Prior to
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