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to pay tax deficiencies over a tax shelter that she viewed as
fraudulent. Her actions in not filing proper tax returns were
nothing more than acts of civil disobedience. Her pleadings, as
noted above, were frivolous and consumed the time and efforts of
this Court. Moreover, her testimony to the Court that the only
relief she sought was the recusal of respondent's attorney
evinced an intent to delay this proceeding and its ultimate
conclusion. The Court holds that petitioner is liable for the
penalty under section 6673 and imposes such penalty in the amount
of $750.
Because of respondent's concessions,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011