Frank C. Verbeck, Jr. - Page 5

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          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.             

















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