Roy Jay Stallard - Page 10

                                       - 10 -                                         
          continued to advance frivolous and/or groundless statements,                
          contentions, and arguments, the Court would be inclined to impose           
          a penalty not in excess of $25,000 on him under section                     
          6673(a)(1).  In total disregard of the admonitions in the Court’s           
          November 17, 2005 Order, petitioner included in the amended                 
          petition and in petitioner’s memorandum in opposition, which he             
          served on respondent on December 6, 2005, and which the Court had           
          filed as petitioner’s response to respondent’s motion,5 state-              
          ments, contentions, and arguments that the Court finds to be                
          frivolous and groundless.                                                   
               Petitioner is no stranger to this Court.  He previously                
          raised frivolous challenges to determinations that the Commis-              
          sioner of Internal Revenue made with respect to certain of his              
          other taxable years.  Stallard v. Commissioner, T.C. Memo. 1992-            
          593.6  In Stallard, we imposed a penalty of $8,000 on petitioner            
          under section 6673(a)(1) because he advanced frivolous arguments            
          in that case.  Id.                                                          
               We find that petitioner remains undeterred in advancing                
          frivolous and groundless statements, contentions, and arguments.            
          We further find that petitioner has instituted this proceeding              

               5The Court had petitioner’s memorandum in opposition filed             
          as petitioner’s response to respondent’s motion as of Feb. 2,               
          2006.                                                                       
               6See Stallard v. Commissioner, 1993 U.S. App. LEXIS 21011              
          (D.C. Cir., June 29, 1993) (granting motion to dismiss appeal for           
          improper venue).                                                            





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011