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with respect to petitioner’s taxable year 2003 and (2) a clear
and concise statement of the facts that form the basis of peti-
tioner’s assignments of alleged error. We conclude that both the
petition and the amended petition do not comply with the Tax
Court Rules of Practice and Procedure as to the form and content
of a petition.
Moreover, we have found that the petition and the amended
petition contain statements, contentions, and arguments that are
frivolous and/or groundless. “A petition that makes only frivo-
lous and groundless arguments makes no justiciable claim”. Nis
Family Trust v. Commissioner, 115 T.C. 523, 539 (2000); see also
Funk v. Commissioner, 123 T.C. 213, 216-217 (2004) (a petition
and an amended petition did not state a claim upon which relief
may be granted where they lacked a clear statement of error and
contained “nothing more than frivolous rhetoric and legalistic
gibberish”).
We find that petitioner’s claims in the petition and the
amended petition state no justiciable basis upon which relief may
be granted.
In respondent’s motion, respondent also asks the Court to
impose a penalty on petitioner under section 6673. Section
6673(a)(1) provides in pertinent part:
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Last modified: May 25, 2011