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IV. Frivolous Suit
Under section 6673, this Court may require a taxpayer to pay
a penalty not to exceed $25,000 if the taxpayer takes a frivolous
position in the proceeding or institutes the proceeding primarily
for delay. A position maintained by the taxpayer is “frivolous”
where it is “contrary to established law and unsupported by a
reasoned, colorable argument for change in the law.” Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986). Petitioner’s
arguments concerning the underlying deficiency amount to tax
protester rhetoric and are manifestly frivolous and groundless.
He has wasted the time and resources of this Court. Accordingly,
we shall impose a penalty of $5,000 pursuant to section 6673.
To the extent not herein discussed, we have considered the
parties’ other arguments and found them to be meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011