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