- 3 - Control Number”. This Court and other courts have encountered these and similar arguments repeatedly and we have repeatedly rejected these arguments as frivolous. See, e.g., Rowlee v. Commissioner, 80 T.C. 1111 (1983); Crow v. Commissioner, T.C. Memo. 1995-584, affd. per curiam 92 F.3d 1177 (4th Cir. 1996); Allnutt v. Commissioner, T.C. Memo. 1991-6, affd. per curiam 956 F.2d 1162 (4th Cir. 1992); Sterner v. Commissioner, T.C. Memo. 1989-352; Kearse v. Commissioner, T.C. Memo. 1988-249, affd. per curiam 883 F.2d 69 (4th Cir. 1989). The Court, therefore, on its own motion, grants summary judgment with respect to these issues and sustains respondent’s determinations. In many of the cases cited above we awarded penalties under section 6673. Section 6673(a) provides that, if the Court determines that proceedings are maintained by a taxpayer primarily for delay or the position of a taxpayer is groundless or frivolous, the Court may award penalties to the United States in an amount not in excess of $25,000. At the hearing, petitioner acknowledged that he was aware that we have repeatedly rejected his arguments and have imposed penalties in similar cases.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011