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delay, or the taxpayer's position in such proceeding is frivolous
or groundless, the Court may require the taxpayer to pay to the
United States a penalty not in excess of $25,000.
We hold that petitioner has instituted and maintained this
action primarily for delay and that petitioner's position in this
proceeding is frivolous and groundless. Accordingly, in our
decision we will require petitioner to pay to the United States a
penalty of $2,500.
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011