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Respondent's determination of the accuracy-related penalty under
section 6662(a) for 1995 is sustained.
Section 6673(a) provides that, if the Court determines that
the position of the taxpayer is frivolous or groundless or that
the taxpayer instituted or maintained the proceeding primarily
for delay, the Court can award a penalty in an amount not in
excess of $25,000. While we eschew awarding a penalty in these
cases, if petitioner persists in his argument that wages are not
income or other similarly frivolous arguments, we shall not be so
constrained the next time.
Decisions will be
entered for respondent.
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Last modified: May 25, 2011