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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).
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