Robert J. Bivolcic - Page 6
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Levy. The action was dismissed by the United States District
Court, and on his appeal, the United States Court of Appeals for
the Third Circuit affirmed the judgment of the District Court.
While petitioner’s current argument is different from the
one he used in his previous case before us, this argument is no
less frivolous. At the beginning of this trial, the Court
repeatedly and clearly warned petitioner that if he proceeded
with his current argument he would be subject to penalties.
Petitioner knew or should have known his position was groundless
and frivolous, yet he persisted in maintaining this proceeding
primarily to impede the proper workings of our judicial system
and to delay the payment of his Federal income tax liabilities.
Accordingly, a penalty is awarded to the United States under
section 6673 in the amount of $6,000.
Decision will be entered for
respondent as to the deficiency,
and a penalty will be awarded to
the United States under section
6673, and decision will be entered
for petitioner as to the section
6651(a) addition to tax.
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Last modified: May 25, 2011