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chosen to ignore the Court's precedents and admonitions and has
continued to assert frivolous and groundless positions.
Petitioner has wasted valuable time and imposed additional costs
on respondent, the Court, and petitioner's employers and their
accountants by refusing to stipulate the amounts of compensation
that he received from his employers during the taxable years in
question and other facts that were not reasonably in dispute,
including his failures to file returns.
Petitioner apparently followed the Court's advice in
settling the case at docket No. 7944-98, but he has continued to
play his hopeless hand in this case, consciously choosing to risk
the imposition of a penalty under section 6673.
In the face of petitioner's refusal to deal with this case
on the merits, respondent has asked the Court to impose a penalty
under section 6673 in the full amount permitted by law, $25,000.
The Court agrees with respondent that a substantial penalty is
appropriate, but, considering the total amount owed by
petitioner, not in the full amount of $25,000. We will exercise
our discretion under section 6673 to require petitioner to pay a
penalty to the United States in the amount of $10,000.
An appropriate order will
be issued, and decision will be
entered for respondent.
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Last modified: May 25, 2011