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On this record, the Court holds that petitioner has
instituted and maintained these proceedings primarily for
purposes of delay, and that petitioner's position that his
earnings are exempt from income tax is frivolous and groundless.
Thus, the Court hereby imposes upon petitioner a penalty in each
case, under section 6673, in the amount of $250 in favor of the
United States.
Decisions will be entered
for respondent.
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Last modified: May 25, 2011