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However, we regard this case as fair warning to those taxpayers
who, in the future, institute or maintain a lien or levy action
primarily for delay or whose position in such a proceeding is
frivolous or groundless. See White v. Commissioner, 72 T.C.
1126, 1135-1136 (1979) (providing fair warning to taxpayers in
deficiency actions who bring frivolous case merely for purposes
of delay).
To reflect the foregoing,
An order of dismissal and
decision will be entered.
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Last modified: May 25, 2011