Opinion
29513-21
01-31-2022
ORDER OF DISMISSAL AND DECISION
Lewis R. Carluzzo Chief Special Trial Judge
In the Order of Dismissal, entered and served November 8, 2021, petitioner was advised that submitting a document that advances the frivolous position she has taken in this case would result in the imposition of an I.R.C. section 6673(a) penalty. She was again advised in the Order served November 10, 2021, issued in response to her motion for default and dismissal filed November 8, 2021. Nevertheless, she submitted one, namely, the "Answer" filed January 24, 2022. Because she did so, and in order to give effect to the imposition of an I.R.C. section 6673 penalty, it is
ORDERED that the above referenced Order of Dismissal is vacated and set aside. It is further
ORDERED that for the reasons set forth in that Order of Dismissal here vacated, this case is dismissed. It is further
ORDERED and DECIDED that because the position petitioner has taken in this proceeding is frivolous and groundless, she shall pay to the United States a $1,500 I.R.C. section 6673(a) penalty.