- 6 - Levy. The action was dismissed by the United States District Court, and on his appeal, the United States Court of Appeals for the Third Circuit affirmed the judgment of the District Court. While petitioner’s current argument is different from the one he used in his previous case before us, this argument is no less frivolous. At the beginning of this trial, the Court repeatedly and clearly warned petitioner that if he proceeded with his current argument he would be subject to penalties. Petitioner knew or should have known his position was groundless and frivolous, yet he persisted in maintaining this proceeding primarily to impede the proper workings of our judicial system and to delay the payment of his Federal income tax liabilities. Accordingly, a penalty is awarded to the United States under section 6673 in the amount of $6,000. Decision will be entered for respondent as to the deficiency, and a penalty will be awarded to the United States under section 6673, and decision will be entered for petitioner as to the section 6651(a) addition to tax.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011