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are frivolous.4 We also conclude from the facts of this case
that petitioners have instituted and maintained this proceeding
primarily for delay.5 Accordingly, pursuant to section 6673, we
require them to pay to the United States a penalty of $2,500.
We have considered all arguments and have found those
arguments not discussed herein to be irrelevant and/or without
merit. To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
4 We also note that we recognize petitioners’ response to
respondent’s motion for summary judgment as generally a
repetition of the same language set forth in similar responses
filed in this Court by other taxpayers challenging a lien or
proposed levy.
5 The fact that petitioners are not indifferent to wasting
the judiciary’s resources in an attempt to delay the respondent’s
collection of their tax liability is further evidenced by their
having commenced an action first in Federal District Court.
Petitioners commenced that action there after having received a
notice of determination which recited that this Court, not a
District Court, is the proper forum in which to litigate this
matter.
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Last modified: May 25, 2011