- 3 - 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/orPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011