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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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