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and arguments set forth in petitioner’s proposed stipulation of
facts and petitioner’s February 28, 2003 transmittal letter are
frivolous and/or groundless. In the March 10, 2003 Order, the
Court reminded petitioner about section 6673(a) and admonished
him that, in the event he continued to advance frivolous and/or
groundless contentions and arguments, the Court would be inclined
to impose a penalty not in excess of $25,000 on him under section
6673(a)(1).
On March 10, 2003, petitioner submitted petitioner’s trial
memorandum to the Court. In an Order dated March 11, 2003 (March
11, 2003 Order), the Court ordered petitioner’s trial memorandum
to be filed as of the date of receipt by the Court. In that
Order, the Court found that petitioner’s trial memorandum set
forth issues, statements, contentions, and arguments that are
frivolous and groundless. In the Court’s March 11, 2003 Order,
the Court reminded petitioner about its March 10, 2003 Order and
issued a second reminder to petitioner about section 6673(a) and
a second admonition to him that, in the event he continued to
advance frivolous and/or groundless statements, contentions, and
arguments, the Court would be inclined to impose a penalty not in
excess of $25,000 on him under section 6673(a)(1).
On March 24, 2003, at the call of this case from the calen-
dar (calendar call) at the Court’s trial session in Chicago,
Illinois, the Court again reminded petitioner that, in the event
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Last modified: May 25, 2011