Opinion
6501-20
12-18-2023
ANDREW P. MATTSON & LINDSEY J. MATTSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge.
On December 15, 2023, petitioners filed a Motion in Limine to Exclude Closing Agreement from Evidence. That motion is frivolous and will be denied. We caution petitioners that taking frivolous positions may result in the imposition of sanctions. Section 6673(a)(1) provides, "Whenever it appears to the Tax Court that ... the taxpayer's position in such proceeding is frivolous or groundless ... the Tax Court, in its decision, may require the taxpayer to pay to the United States a penalty not in excess of $25,000."
In reviewing the motion, the Court notes that petitioners' address as stated in the Motion differs from their address of record. And in reviewing the record of this case, the Court noted that petitioners have not provided a telephone number at which they can be contacted. Accordingly, it is
ORDERED that petitioners' Motion in Limine to Exclude Closing Agreement from Evidence filed December 15, 2023, is denied. It is further
ORDERED that petitioners shall filed a Notice of Change of Address in which they advise the Court of their current address and telephone number.