- 14 - responsive answers and denials to respondent's Third Request for Admissions, the case could have been settled or tried on the merits, which would have resulted in the Court's exercise of its judicial function in the traditional way. We conclude, with respect to the second phase of this case, that petitioners' failures to respond and appear have caused the further proceedings herein to have been "maintained by the taxpayer primarily for delay" within the meaning of section 6673(a)(1). We therefore shall require petitioners to pay an additional penalty of $1,000, to be added to the $10,000 penalty previously decided by reason of petitioners' frivolous and groundless arguments with respect to the first phase of this case. An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011