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authorized to impose “monetary sanctions of up to $25,000 for
instituting or maintaining an action before it primarily for
delay or for taking a position that is frivolous or groundless”,
and stated that petitioner’s positions in this case had no merit
and were groundless.
Petitioner submitted a timely petition appealing
respondent’s determination, which we filed on April 1, 2004. In
an addendum attached to the petition, petitioner asserted, inter
alia, that the Internal Revenue Service (IRS) had not established
that he was a taxpayer, that the hearing was a sham, that Ms.
Chadwell was biased, and that the law did not create the alleged
obligation.
On October 6, 2004, we received and filed respondent’s
summary judgment motion. By order dated October 6, 2004, we
ordered petitioner to file a response to respondent’s motion on
or before October 27, 2004. Petitioner did not do so.2 On
November 3, 2004, we received and filed petitioner’s motion to
strike respondent’s motion for summary judgment, which we denied
on November 4, 2004.
2Petitioner submitted a response to respondent’s motion on
Dec. 1, 2004, but it was returned to petitioner as untimely. On
Dec. 17, 2004, petitioner submitted a document entitled
“Petitioner’s motion accept response as timely”, which we filed
as of that date and denied on Dec. 23, 2004. The response that
was attached repeated the arguments contained in the petition and
other submissions.
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