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administrative resources. Previously, on its own motion, this
Court has awarded damages to the United States under section 6673
where the taxpayer advanced frivolous and groundless contentions
similar to those advanced by petitioner. See Abrams v.
Commissioner, 82 T.C. 403, 408-413 (1984). Although we do not
now impose a penalty under section 6673(a)(1), we caution
petitioner that if he continues to advance such arguments to this
Court, he will invite such penalties in the future.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011