Opinion
22564-21
12-17-2021
Derrick Shawton Gonzalez Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Lewis R. Carluzzo Chief Special Trial Judge
Because neither Court practice nor the Tax Court Rules of Practice and Procedure contemplate the filing of such a document after a case has been dismissed, it is ORDERED that the document styled "Consent Decree" received from petitioner and filed on December 8, 2021, is stricken.
Petitioner's attention is invited to I.R.C. section 6673(a). If it appears to the Court that a taxpayer's position in a proceeding before the Court is frivolous or groundless, then the Court can impose a penalty (not to exceed $25,000) on that taxpayer. Petitioner is advised that it appears to the Court that the position he has taken in this case is frivolous or groundless. No penalty will be imposed at this time. However, future submissions advancing a frivolous or groundless position will result in the imposition of a penalty. 1