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rejected petitioner's contentions and also imposed a penalty of
$10,000.
Based on the petition filed by petitioner, we believe
petitioner is interested in disputing the merits of the
deficiencies in income tax and the additions to tax as determined
by respondent in the notice of deficiency. Accordingly, we will
deny respondent's motion to impose a penalty. However, we
caution petitioner that a continued persistence in frivolous and
groundless protester allegations will subject him to a penalty
under the provisions of section 6673.
In order to reflect the foregoing,
An order denying respondent's
motion and striking a portion of
the petition will be issued.
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