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On September 29, 2004, the District Court entered an injunc-
tion order against Mr. Hassell (District Court’s September 29,
2004 injunction order) that provided in pertinent part:
As a consequence of Hassell’s non-compliance with
prior court orders, a more expansive injunction is
warranted.
It is therefore ORDERED that the clerk of this
court shall not accept from Melvin R. Hassell any
pleadings or documents in this case, or in any other
case filed or to be filed within this district, unless
Hassell first obtains leave from this court to make
such filing.
It is further ORDERED that Melvin R. Hassell shall
not file any pleadings or documents in this case or in
any other case, including as yet unfiled lawsuits,
either in federal court or any state court, unless he
first obtains leave from this court to make such fil-
ing. * * *
It is further ORDERED that should Melvin R.
Hassell violate this order, then he may again be held
in criminal contempt of court.[7] [Fn. refs. omitted.]
The respective literal transcripts for petitioner’s taxable
years 1980 and 1981 that respondent sent to petitioner by cover
letter dated February 2, 2005 (respondent’s February 2, 2005
letter) reflect that, at least as early as January 10, 2005,
petitioner did not have an unpaid liability with respect to his
7On Sept. 21, 2005, the District Court issued an order
(District Court’s Sept. 21, 2005 order) finding that Mr. Hassell
(1) had willfully violated the District Court’s September 29,
2004 injunction order by filing a suit in the District Court
without first obtaining leave of the District Court and (2) was
guilty of criminal contempt. On Oct. 17, 2005, Mr. Hassell filed
a notice of appeal with the Fifth Circuit with respect to the
District Court’s Sept. 21, 2005 order. On Jan. 18, 2006, the
Fifth Circuit dismissed that appeal for want of prosecution.
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