- 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.
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Last modified: May 25, 2011