- 5 -
Court. On the basis of well-established law, we find that
petitioner's position is frivolous and groundless.
The record in these cases convinces us that petitioner was
not interested in disputing the merits of either the deficiencies
in income taxes or the additions to tax determined by respondent
in the respective notices of deficiency. Rather, the record
demonstrates that petitioner regards these cases as vehicles to
espouse his own misguided view of the tax laws of this country.
We are also convinced that petitioner instituted and
maintained these proceedings primarily, if not exclusively, for
purposes of delay. Dealing with these matters wasted the Court's
time and respondent's time, and taxpayers with genuine
controversies were delayed.
In view of the foregoing, we shall exercise our discretion
under section 6673(a)(1) and require petitioner to pay penalties
to the United States in the total amount of $25,000. See Fox v.
Commissioner, 969 F.2d 951, 953 (10th Cir. 1992), affg. T.C.
Memo. 1991-240; Crain v. Commissioner, 737 F.2d 1417, 1417-1418
(5th Cir. 1984); Coulter v. Commissioner, 82 T.C. 580, 584-586
(1984).
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011