- -9
on the grounds that this case was instituted primarily for delay
and that petitioner's position in the case is frivolous or
groundless, except the argument that the income tax is an excise
tax which is not applicable to his income.
The Court, therefore, determines that respondent's motion
for judgment on the pleadings is granted. The Court further
holds that petitioner is required to pay to the United States a
penalty of $5,000 under the provisions of section 6673.
An order granting respondent's motion for
judgment on the pleadings will be entered, and
decision will be entered for respondent in
accordance with the determination in the notice
of deficiency and the penalty determined herein.
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Last modified: May 25, 2011