BRIGHT, Circuit Judge.
Appellant Richard May appeals from the Tax Court's dismissal of his petition contesting the Commissioner's deficiency determination in his federal income taxes for failure to state a claim and its decision, sua sponte, to impose $5,000 damages against him pursuant to section 6673 of the Internal Revenue Code. We affirm.
I. BACKGROUND.
On February 24, 1983, May received from the Commissioner of Internal Revenue a notice of deficiency...
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