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frivolous and groundless. In the Court’s November 17, 2005
Order, the Court reminded petitioner about section 6673(a)(1) and
admonished him as follows:
In the event that petitioner continues to advance
frivolous and/or groundless statements, contentions,
and arguments, 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 December 6, 2005, the Court received from petitioner one
document (petitioner’s document) which contained (1) “PETI-
TIONER’S MEMORANDUM IN OPPOSITION TO RESPONDENT’S MOTION TO
DISMISS FOR FAILURE TO STATE A CLAIM UPON WHICH RELIEF CAN BE
GRANTED AND TO IMPOSE A PENALTY UNDER I.R.C. � 6673” and (2) an
“AMENDED PETITION”. On December 7, 2005, the Court had that
document returned to petitioner unfiled because an amended
petition must be separate from any other document furnished to
the Court and must bear petitioner’s original signature.
On January 6, 2006, petitioner filed an amended petition.
In total disregard of the Court’s November 17, 2005 Order,
petitioner included in the amended petition statements, conten-
tions, and arguments that the Court finds to be frivolous and
groundless. For example, the amended petition states in perti-
nent part:
ASSIGNMENTS OF ERROR, FACTUAL BASIS AND
RELIEF REQUESTED
a.
The notice of deficiency is notice in name only and
does not meet due process of law requirements for notice
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Last modified: May 25, 2011