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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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