Peter T. Storaasli - Page 12

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          to strike portions of the petition on the grounds that it                   
          contained immaterial, frivolous, and nonjusticiable arguments and           
          that it did not contain clear and concise assignments of error or           
          lettered statements of the facts upon which to base assignments             
          of error, as required by Rule 34(b)(4) and (5).  On August 21,              
          2003, we granted respondent’s motion to strike.                             
               By letter dated February 5, 2004, respondent advised                   
          petitioner that he considered several of the arguments in the               
          petition to be immaterial and frivolous and that he would request           
          that the Court award damages under section 6673 in an amount not            
          to exceed $25,000 if petitioner persisted, at trial, in advancing           
          groundless arguments that did not pertain to the amount of tax              
          due.  On February 26, 2004, at the beginning of trial,                      
          respondent’s motion for sanctions under section 6673(a)(1)(B) was           
          filed.  We reserved ruling on the motion and address it in the              
          opinion that follows.                                                       
               At trial, we warned petitioner on several occasions that we            
          would not entertain any arguments at trial or on brief regarding            
          the source of the Federal taxing authority or the basis for                 
          respondent’s contention that income from the sale of property is            
          taxable under the laws of the United States.  We further                    
          explained to petitioner that personal labor is neither includable           
          in basis nor deductible as an expense, that any arguments                   
          regarding the tax treatment of personal labor are frivolous,                






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