Opinion
30263-21
01-31-2022
ORDER OF DISMISSAL AND DECISION
Lewis R. Carluzzo, Chief Special Trial Judge
In the Order of Dismissal, entered and served November 16, 2021, petitioner was advised that submitting a document that advances the frivolous position he has taken in this case would result in the imposition of an I.R.C. section 6673(a) penalty. Nevertheless, he submitted one, namely, the "Answer" filed January 24, 2022. Because he 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, he shall pay to the United States a $1,500 I.R.C. section 6673(a) penalty.