Melvin Ray Hassell - Page 14

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          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).  We             





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