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situations. It is inappropriate that taxpayers who promptly pay
their taxes should have the cost of government and tax collection
improperly increased by frivolous arguments already fully
considered and rejected by the courts.
Hence, petitioner received fair warning but has persisted in
disputing respondent’s determination. The Court concludes that a
section 6673 penalty of $3,000 should be awarded to the United
States in this case. To reflect the foregoing,
An appropriate order
granting respondent’s motion
and decision for respondent
will be entered.
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Last modified: May 25, 2011