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groundless. See sec. 6673. Based on the record, we conclude
that such an award is appropriate in this case. Petitioner’s
argument that he can escape liability for income tax by
purporting to assign earnings from his personal activities to a
series of trusts is frivolous. Accordingly, a penalty is awarded
to the United States under section 6673 in the amount of $5,000.
We have considered all arguments in this case. Those
arguments not discussed herein are without merit or irrelevant.
To reflect the foregoing,
An appropriate order will be
issued granting respondent’s motion
for a penalty, and decision will be
entered under Rule 155.
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