Lionel D. Kolker - Page 6

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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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