Opinion
13672-22
08-30-2022
LEONARD RAYMOND NOWAKOWSKI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Lewis R. Carluzzo, Chief Special Trial Judge.
For the reasons contained in respondent's motion to dismiss, filed August 4, 2022, it is ORDERED that respondent's motion is granted and this case is dismissed.
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.