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Petitioner was warned before and during trial about the
likelihood that a penalty would be awarded to the United States
if he continued to pursue his groundless and frivolous arguments.
See sec. 6673. His response was that “with all the money at
stake, it didn’t really matter.” The large deficiencies,
additions to tax, and penalties owed by petitioner resulted from
his fraudulent failure to file returns. They are not a reason
not to impose a penalty under section 6673 for his maintenance of
frivolous positions in this case. Considering the entire record,
a penalty should be imposed and will be awarded to the United
States in the amount of $25,000. See, e.g., Kowalik v.
Commissioner, T.C. Memo. 1990-363.
Decision will be entered
for respondent.
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Last modified: May 25, 2011