- 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