- 14 - contentions, arguments, and/or requests that the Court finds to be frivolous and/or groundless. On February 22, 2006, the Court issued an Order (Court’s February 22, 2006 Order) in which, inter alia, the Court reminded petitioner about section 6673(a)(1) and admonished him as fol- lows: In the event that petitioner advances frivolous and/or groundless statements, contentions, and arguments in petitioner’s response to respondent’s motion ordered herein * * * 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 March 8, 2006, petitioner filed a response to respon- dent’s motion (petitioner’s response). Petitioner’s response contains statements, contentions, arguments, and/or requests that the Court finds to be frivolous and/or groundless. On March 28, 2006, petitioner submitted three documents that the Court had filed as petitioner’s supplement to petitioner’s response (petitioner’s supplement to petitioner’s response). Petitioner’s supplement to petitioner’s response contains state- ments, contentions, arguments, and/or requests that the Court finds to be frivolous and/or groundless. Discussion The Court may grant summary judgment where there is no genuine issue of material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). WePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011