Arlie G. Curry, Jr. - Page 7

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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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