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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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Last modified: May 25, 2011