In Uncategorized on 12/02/2021 at 12:02

When CSTJ Lewis (“Spelled Right”) Carluzzo issues an invitation, it’s well to heed it. While he may not be able to give recusants the Luke 14:23 treatment, it may yet be unpleasant to say “no.”

CSTJ Lew extends the invitation to Nivaldo Souza & Ivonete Souza, Docket No. 32006-21*, filed 12/2/21, after tossing their petition for failure to state a claim.

“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.” Order, at p. 1.

And it’s beginning to look a lot like frivolity to CSTJ Lew.

No chop today, but heed the invitation.

*Nivaldo and Ivonette Souza Docket No 32006-21 12 2 21


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