Nicholas Mack - Page 10




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          also be sanctioned by means of a penalty imposed under section              
          6673.  Initially we note that petitioner’s conduct meets the                
          letter and intent of section 6673 in that his personal attacks on           
          respondent’s and the Court’s employees are frivolous.  Petitioner           
          has not advanced any particular reasons for his broad-based                 
          claims of fraud and misconduct.  In addition, he has failed to              
          present any meaningful basis to support his generalized claim               
          that respondent’s determinations are in error.  Finally, after              
          instituting these proceedings, petitioner has sought to engineer            
          a delay of them.  He has made unreasonable ultimatums, refused to           
          cooperate or follow the Court’s Rules, and most significantly,              
          intentionally refused to accept, read, or follow the Court’s                
          correspondence, some of which contains Court orders requiring a             
          specific action.                                                            
               Petitioner’s income tax deficiencies are modest ($554 for              
          2003 and $1,142 for 2004), but his belligerence and actions                 
          require that, in addition to the dismissal of his cases, he be              
          sanctioned by the imposition of penalties under section 6673 of             
          $1,000 for 2003 and $1,000 for 2004.  Petitioner’s attempts to              
          delay and his belligerence must be sanctioned to vindicate the              
          integrity of this Court’s proceedings and to deter petitioner               
          from similar misconduct in the future.  Accordingly, we will                
          grant respondent’s motions to impose sanctions under I.R.C.                 
          section 6673.                                                               







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