- 3 - This argument is frivolous. See secs. 61, 72, 402(a); see also Rowlee v. Commissioner, 80 T.C. 1111, 1119-1122 (1983). Respondent asks that a penalty be imposed under section 6673. That section provides, inter alia, that if it appears to this Court that “the taxpayer’s position * * * is frivolous or groundless”, the Court may impose a penalty in an amount not in excess of $25,000. Sec. 6673(a). This Court cautioned petitioner at the calendar call and at the trial that the positions he espoused were frivolous and warned him of the provisions of section 6673. Petitioner did not heed these warnings. We therefore award a penalty to the United States against petitioner in the amount of $1,500. An appropriate order and decision will be entered.Page: Previous 1 2 3
Last modified: May 25, 2011