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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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Last modified: May 25, 2011