- 6 -
procedure” on a point of law regarding the nature of the income
tax. On September 27, 2001, the Court denied this motion.
On September 17, 2001, petitioner filed a motion to quash
subpoena duces tecum. The subpoena required petitioner to appear
30 minutes before the trial and to bring certain documents with
him. On October 5, 2001, the Court denied this motion.
On October 23, 2001, petitioner filed a motion for
reconsideration of the Court’s order of October 5, 2001. On
October 24, 2001, the Court denied this motion.
On December 3, 2001, over a month after the trial of this
case, petitioner filed a motion to reconsider the denial of
motion to quash subpoena duces tecum. On December 11, 2001, the
Court denied this motion.
At trial, the Court warned petitioner that his arguments
were frivolous and of the provisions of section 6673. Petitioner
filed several frivolous documents with the Court. Petitioner’s
position, based on stale and meritless contentions, is manifestly
frivolous and groundless, and he has wasted the time and
resources of this Court. Accordingly, we shall impose a penalty
of $12,500 pursuant to section 6673.
To reflect the foregoing,
Decision will be
entered for respondent.
Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011