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earlier decision, involving 1989, was consolidated with their
appeal of a dismissal by a District Court of their action seeking
a refund of a $500 penalty imposed for filing a frivolous tax
return. The Court of Appeals not only sustained the courts below
but imposed its own sanction by awarding the United States double
costs plus $1,000 in damages for the frivolous appeals. See
Sochia v. Commissioner, 23 F.3d 941, 944 (5th Cir. 1994).
As petitioners have already been amply notified, their
position is frivolous and groundless. We therefore exercise our
discretion under section 6673(a)(1) and require petitioners to
pay a penalty to the United States in the amount of $5,000 for
each of the years here in issue.
In order to reflect concessions made by respondent,
An appropriate order
will be issued and decision
will be entered under Rule
155.
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Last modified: May 25, 2011