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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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Last modified: March 27, 2008