- 18 - short, having to deal with this matter wasted the Court's time, as well as respondent's, and taxpayers with genuine controversies may have been delayed. Also relevant is the fact that petitioner is well aware of the provisions of section 6673. After all, petitioner attached to his petition and/or motion to dismiss a copy of Davis v. Commissioner, T.C. Memo. 2001-87, in which this Court sustained the Commissioner’s determination to proceed with collection and imposed a $4,000 penalty under section 6673(a) against the taxpayer. Moreover, in its Order dated December 20, 2001, denying his motion to dismiss, the Court expressly warned petitioner about the possibility of imposing a penalty under section 6673. Under the circumstances, we shall grant that part of respondent’s motion that moves for the imposition of a penalty in that we shall impose a penalty on petitioner pursuant to section 6673(a)(1) in the amount of $1,500. In order to give effect to the foregoing, An appropriate order granting respondent's motion and decision for respondent will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011