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the petition of specific justiciable allegations of error and of
supporting facts, this Court shall grant respondent’s motion.
See Funk v. Commissioner, supra.
Section 6673(a)(1) authorizes this Court to require a
taxpayer to pay to the United States a penalty not in excess of
$25,000 whenever it appears that proceedings have been instituted
or maintained by the taxpayer primarily for delay or that the
taxpayer's position in such proceeding is frivolous or
groundless. The Court has considered imposing sanctions on
petitioner under section 6673(a)(1) but declines to do so at this
time. With this in mind, we note that petitioner is now on
notice that he may be liable for sanctions if he continues to
make frivolous arguments and maintain proceedings before this
Court for the purpose of delay.
Accordingly, we shall dismiss petitioner’s case and enter a
decision sustaining respondent’s determinations contained in the
notice of deficiency dated June 9, 2005. See sec. 7459(d).
To reflect the foregoing,
An appropriate order of
dismissal and decision will be
entered for respondent.
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Last modified: May 25, 2011