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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.
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Last modified: May 25, 2011