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inter alia, he is not liable for income tax on the wages that he
received during the years 1984 throughout 1988 and that he was a
nonresident alien during those years are frivolous and ground-
less. We further conclude that petitioner instituted and main-
tained this proceeding primarily for delay. Accordingly, we hold
that petitioner is liable for a penalty under section 6673 in the
amount of $25,000.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011