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when the taxpayer has instituted proceedings primarily for delay,
the taxpayer's position is frivolous or groundless, or the
taxpayer unreasonably failed to pursue administrative remedies.
Respondent has not requested that the Court exercise its
authority, and the Court declines to do so sua sponte in the
instant proceedings. However, petitioners are cautioned that
this sanction is available to the Court and will be considered if
petitioners persist in pursuing frivolous arguments before this
Court.
An appropriate order will be
issued, and decisions will be
entered for respondent.
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Last modified: May 25, 2011