- 5 - justiciable issues, and respondent's motion to dismiss will be granted. Section 6673 authorizes this Court to impose a penalty in favor of the United States, in an amount not to exceed $25,000 whenever it appears that the taxpayer's position in a proceeding is frivolous, groundless, or instituted primarily for delay. Petitioner's actions are clearly frivolous. Indeed, his only apparent reason to file a petition with this Court to challenge our jurisdiction was to delay assessment and collection of his income tax liabilities. Accordingly, we will require petitioner to pay to the United States a penalty of $10,000 pursuant to section 6673. An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011