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had no authority to impute * * * [an entity’s] income to * * *
[the taxpayers].” In addition to section 6673 penalties imposed
by the Tax Court, the Court of Appeals for the Fifth Circuit in
Sandvall v. Commissioner, supra, awarded $3,000 in damages, in
part, because of the taxpayers’ “frivolous and meaningless
arguments.” Id. at 460.
Because petitioner unreasonably failed to avail himself of
his administrative remedies and, more particularly, because
petitioner has advanced frivolous arguments, we hold that he is
liable for a $5,000 penalty under section 6673.
To reflect the foregoing,
An appropriate order and decision
will be entered.
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Last modified: May 25, 2011