- 5 - attention to specific pages of “The Truth About Frivolous Tax Arguments” regarding petitioner’s contentions. On August 21, 2006, respondent filed a motion for summary judgment and to impose a penalty under section 6673. On August 24, 2006, the Court ordered petitioner to file on or before September 8, 2006, any objection to respondent’s motion for summary judgment and to impose a penalty under section 6673. On September 5, 2006, petitioner filed an objection to respondent’s motion for summary judgment and to impose a penalty under section 6673. In the objection, petitioner made frivolous and groundless arguments. On September 12, 2006, the Court ordered respondent’s motion for summary judgment and to impose a penalty under section 6673 calendared for hearing at the Court’s San Diego, California, session beginning September 25, 2006. Petitioner appeared at the calendar call and made an oral motion for a continuance which the Court denied. At the hearing on respondent’s motion for summary judgment and to impose a penalty under section 6673, petitioner filed a supplemental response to motion for summary judgment. At the hearing, petitioner made several frivolous objections which the Court denied. Petitioner was evasive in answering the Court’s questions.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007