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file a written response to respondent’s motion by January 31,
2006.
On January 9, 2006, the Court received from petitioner a
“Certificate of Service” (petitioner’s certificate of service),
but no document was submitted to the Court with that certificate.
On January 13, 2006, the Court had petitioner’s certificate of
service returned to petitioner unfiled with a reminder to peti-
tioner that a written response to respondent’s motion must be
received by the Court by January 31, 2006. The Court did not
receive from petitioner any such written response.
On February 2, 2006, respondent filed a supplement to
respondent’s motion (respondent’s supplement to respondent’s
motion). Respondent attached as an exhibit to that supplement a
document entitled “PETITIONER’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” (petitioner’s memorandum in opposition) that petitioner
served on respondent on December 6, 2005. In total disregard of
the Court’s November 17, 2005 Order, petitioner included in
petitioner’s memorandum in opposition that petitioner served on
respondent on December 6, 2005, statements, contentions, and
arguments that the Court finds to be frivolous and groundless.
On February 22, 2006, the Court issued an Order in which it
ordered the Clerk of the Court to file as of February 2, 2006, as
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