Robert M. Temple - Page 31




                                       - 31 -                                         
          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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