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Internal Revenue Service, North Carolina Department of
Revenue, fuel bills and other obligations just to name
a few. Time is stolen from family and friends.
On June 13, 2005, petitioner filed with the Court a motion
to dismiss, which the Court denied. Petitioner’s motion to
dismiss contained statements, contentions, arguments, and re-
quests that the Court finds to be frivolous and/or groundless.4
Discussion
The Court may grant summary judgment where there is no
genuine issue of material fact and a decision may be rendered as
a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner,
98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). We
conclude that there are no genuine issues of material fact
regarding the questions raised in respondent’s motion for summary
judgment.
Petitioner did not file a petition with the Court with
respect to the notice of deficiency that respondent issued to her
relating to her taxable years 1997, 1998, and 1999. Where, as is
the case here, the validity of the underlying tax liability is
not properly placed at issue, the Court will review the determi-
nation of the Commissioner of the Internal Revenue for abuse of
4The frivolous and/or groundless statements, contentions,
arguments, and requests in petitioner’s motion to dismiss are
similar to the frivolous and/or groundless statements, conten-
tions, arguments, and requests in documents filed by certain
other taxpayers with cases in the Court. See, e.g., Fink v.
Commissioner, T.C. Memo. 2003-61; Smith v. Commissioner, supra.
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