- -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.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011