- 9 - there are no genuine issues of material fact and that respondent is entitled to summary judgment as a matter of law. On the basis of our review of the record, we find that respondent did not abuse his discretion in sustaining the tax lien. Section 6673(a)(1) authorizes the Tax Court to require a taxpayer to pay to the United States a penalty no greater than $25,000 whenever it appears that proceedings have been instituted or maintained by the taxpayer primarily for delay or that the taxpayer’s position in such proceedings is frivolous or groundless. Although we do not impose a section 6673 penalty on petitioner today, we strongly warn him that if he advances similar frivolous arguments in this Court in the future, we may impose on him a section 6673 penalty up to the $25,000 maximum allowable amount, even upon our own motion. To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011