Charles J. and Francesca C. Sigerseth - Page 10




                                       - 10 -                                         
               Finally, section 6673(a) authorizes this Court to penalize a           
          taxpayer who (1) institutes or maintains a proceeding primarily             
          for delay, (2) pursues a position in this Court which is                    
          frivolous or groundless, or (3) unreasonably fails to pursue                
          available administrative remedies.  Petitioners’ conduct in this            
          case has convinced us that all of the above factors are present             
          in this proceeding.  Petitioners’ repeated failure to comply with           
          respondent’s discovery requests, even in the face of orders from            
          the Court directing them to do so, has resulted in a waste of               
          limited judicial and administrative resources that could have               
          been devoted to resolving bona fide claims of other taxpayers.              
          See Cook v. Spillman, 806 F.2d 948 (9th Cir. 1986).  Further,               
          petitioners have failed to seek settlement at the administrative            
          level.  Lastly, petitioners’ insistence on making protester type            
          arguments even after we have summarily dismissed them indicates             
          an unwillingness on the part of petitioners to respect the tax              
          laws of the United States.  Accordingly, we shall grant                     
          respondent’s motion and require petitioners to pay a penalty to             
          the United States pursuant to section 6673 in the amount of                 
          $15,000.                                                                    
               To reflect the foregoing,                                              
                                                  An appropriate order and            
                                             decision will be entered.                








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