Malcolm Crow - Page 18




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          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.               










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