Opinion
4263-22
04-18-2023
LOUIS GIANNINI & DAWN GIANNINI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Cary Douglas Pugh Judge
This case is currently set for trial at the Court's June 12, 2023, Milwaukee, Wisconsin trial session. On April 13, 2023, respondent filed a Motion for Summary Judgment, accompanied by an Affidavit of Jacqueline K. Queener in Support of Motion for Summary Judgment. In Giannini v. Commissioner, T.C. Memo. 2022-64, we warned petitioners against pursuing frivolous arguments. Under the provisions of I.R.C. sec. 6673(a)(1), the Court has the authority to impose a penalty of up to $25,000 on a taxpayer who pursues a position that is frivolous or groundless. Upon due consideration and for cause, it is hereby
ORDERED that, on or before May 15, 2023, petitioners shall file a response to respondent's Motion for Summary Judgment.
Petitioners are again advised that if the Court concludes that they have made frivolous arguments or taken groundless positions, or that this case has been initiated or maintained primarily for delay, the Court may impose a penalty not to exceed $25,000 under I.R.C. sec. 6673.