- 8 - groundless. Sec. 6673. Based on the record, we conclude that such an award is appropriate in this case. Petitioner has pursued a frivolous and groundless position throughout this proceeding. At the beginning of this trial, petitioner was clearly warned that if he proceeded with the arguments contained in his written submission, then he would be subject to penalties. Petitioner knew or should have known that 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 $10,000 in each docket. To the extent we have not addressed petitioner's arguments, we have considered them and find them to be without merit. Decision will be entered under Rule 155 in docket No. 10398-98 and decision will be entered for respondent in docket No. 16155-98, and a penalty will be awarded to the United States under section 6673.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011