Opinion
11892-22
06-01-2022
NIVALDO SOUZA & IVONETE SOUZA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Lewis R. Carluzzo Chief Special Trial Judge
There being nothing in the petition that gives rise to a justiciable issue, it is
ORDERED that this case is dismissed because petitioner has failed to state a claim upon which relief can be granted.
Petitioners' 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. Petitioners are advised that it appears to the Court that the position they 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.