Ronald McDougle - Page 7




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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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