Virginia L. Fox v. Commissioner of Internal Revenue

BRORBY, Circuit Judge.

Ms. Fox appeals from two orders and decisions of the United States Tax Court entered May 31, 1991, in this deficiency action, dismissing her petitions for review for failure to state a claim upon which relief may be granted, sustaining the Commissioner’s determinations of deficiencies and additions to tax, and awarding damages to the Commissioner in the total amount of $9,500 because she maintained two frivolous actions. 1 The Commissioner asks us not only to affirm the judgments of the Tax Court but to impose additional sanctions against Ms. Fox for bringing frivolous…