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objections. Since that time, petitioner has filed numerous
lengthy motions and documents with the Court espousing frivolous
positions. Many of the motions have previously been denied. The
Court set for hearing: (1) Respondent’s motion to dismiss for
failure to state a claim and (2) petitioner’s motion for partial
summary judgment.3
On February 9, 2005, the Court ordered petitioner to show
cause in writing on or before March 4, 2005, why a penalty should
not be imposed pursuant to section 6673(a).
On February 22, 2005, petitioner filed a Verified Motion for
Ruling on Petitioner’s Motion to Set Aside Defaults Against the
petitioner Docketed on July 8, 2004, and a Verified Motion for
Findings of Fact and Conclusions at Law. On February 23, 2005,
petitioner filed a Motion to Postpone Answer to Order of February
9, 2004 Until Court Rules on Petitioner’s Motion to Set Aside IRS
Default Against Petitioner. All three motions contain frivolous
allegations and were summarily denied. In response to the Order
to show cause, petitioner filed a document entitled “Verified
Answer to Order to Show Cause Why Penalty Should Not Be Imposed.”
The document is replete with frivolous allegations.4
3 In October 2004, petitioner filed a petition for writ of
mandamus with the U.S. Court of Appeals for the 11th Circuit.
The writ was denied on Dec. 21, 2004.
4 On the same date petitioner filed a “Verified Motion to
Certify Issues for Review by the U.S. Court of Appeals for the
(continued...)
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