Blair Hanloh - Page 6

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               SEC. 6673.  SANCTIONS AND COSTS AWARDED BY COURTS.                     
                 *       *       *       *       *       *       *                    
               (1) * * * Whenever it appears to the Tax Court that--                  
                         (A) proceedings before it have been insti-                   
                    tuted or maintained by the taxpayer primarily for                 
                    delay, [or]                                                       
                         (B) the taxpayer’s position in such a pro-                   
                    ceeding is frivolous or groundless, * * *                         
               the Tax Court, in its decision, may require the tax-                   
               payer to pay to the United States a penalty not in                     
               excess of $25,000.                                                     
               In the Court’s March 21, 2006 Order, the Court, inter alia,            
          indicated that the petition contains statements, contentions, and           
          arguments that the Court finds to be frivolous and/or groundless.           
          In that Order, the Court reminded petitioner about section                  
          6673(a)(1) and admonished him that, in the event he continued to            
          advance frivolous and/or groundless contentions and arguments,              
          the Court would be inclined to impose a penalty not in excess of            
          $25,000 on him under section 6673(a)(1).  In total disregard of             
          the admonitions in the Court’s March 21, 2006 Order, petitioner             
          included in petitioner’s response, the amended petition, and                
          petitioner’s response to respondent’s motion as supplemented                
          statements, contentions, and arguments that we have found above             
          to be frivolous and/or groundless.                                          
               Petitioner is no stranger to this Court.  He previously                
          advanced frivolous and groundless arguments in Hanloh v. Commis-            
          sioner, docket No. 11986-05L.  In that case, on November 7, 2005,           





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