Cynthia P. Bullock - Page 3

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          upon which relief can be granted.  Petitioner filed an amended              
          petition repeating frivolous arguments set forth in the petition.           
          Respondent’s motion to dismiss was granted by order entered                 
          June 29, 2004, which contained the following:                               
                    Section 6673(a)(1) authorizes the Tax Court to                    
               require a taxpayer to pay to the United States a                       
               penalty not in excess of $25,000 whenever it appears                   
               that proceedings have been instituted or maintained by                 
               the taxpayer primarily for delay or that the taxpayer’s                
               position in such proceeding is frivolous or groundless.                
               Although we will not impose a penalty upon petitioner                  
               pursuant to section 6673, we nevertheless will take                    
               this opportunity to admonish petitioner that the Court                 
               will consider imposing such a penalty should she return                
               to the Court and advance similar arguments in the                      
               future.                                                                
               The present case was filed on September 7, 2004, with                  
          respect to petitioner’s liability for 2002.  Petitioner filed a             
          frivolous petition, a frivolous motion for summary judgment, a              
          frivolous motion to vacate the order denying the motion for                 
          summary judgment, and various other frivolous documents.  The               
          case was set for trial in Cincinnati, Ohio, on June 12, 2006,               
          pursuant to notice served January 9, 2006.  Petitioner failed to            
          comply with the Court’s Rules or with the standing pretrial order           
          served with the notice of trial.  Instead, on June 1, 2006,                 
          petitioner filed a frivolous motion to dismiss, requesting                  
          withdrawal of the petition.  That motion was denied June 1, 2006.           
               Petitioner failed to appear for trial.  Respondent appeared            
          and filed a pretrial memorandum and a motion for judgment by                
          default.  Respondent’s moving papers included a section 6020(b)             





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