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On March 21, 2006, the Court issued an Order (Court’s March
21, 2006 Order) in which, inter alia, the Court indicated that
the petition contains statements, contentions, and arguments that
the Court finds to be frivolous and/or groundless. In the
Court’s March 21, 2006 Order, the Court also reminded petitioner
about section 6673(a)(1) and admonished him as follows:
In the event that petitioner continues to advance
frivolous and/or groundless contentions and arguments,
the Court will be inclined to impose a penalty not in
excess of $25,000 on petitioner under section
6673(a)(1), I.R.C.
On April 7, 2006, the Court received from petitioner a
document entitled “OPPOSITION TO RESPONDANTS [sic] MOTION TO
DISMISS FOR FAILURE TO STATE A CLAIM UPON WHICH RELIEF CAN BE
GRANTED AND TO IMPOSE A PENALTY UNDER I.R.C. 6673 & RESTATEMENT
OF PETITIONERS [sic] CLAIM”. The Court had that entire document
filed as petitioner’s response to respondent’s motion (peti-
tioner’s response) and a part of it filed as an amended petition.
In total disregard of the Court’s March 21, 2006 Order, peti-
tioner included in petitioner’s response and the amended petition
certain statements, contentions, and arguments that the Court
finds to be frivolous and/or groundless. In fact, petitioner
included in petitioner’s response and the amended petition
certain frivolous and/or groundless statements, contentions, and
arguments that are identical to certain frivolous and/or
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Last modified: May 25, 2011