- 11 -
$25,000 a taxpayer who institutes or maintains a proceeding
primarily for delay or pursues a position in this Court which is
frivolous or groundless. Petitioner’s conduct in this case has
convinced us that she maintained this proceeding primarily for
delay. Petitioner’s actions have resulted in a waste of limited
judicial and administrative resources that could have been
devoted to resolving bona fide claims of other taxpayers. Cook
v. Spillman, 806 F.2d 948 (9th Cir. 1986). Petitioner’s
insistence on making frivolous protester type arguments indicates
an unwillingness to respect the tax laws of the United States.
Accordingly, we shall grant respondent’s motion for sanctions and
require petitioner to pay a penalty to the United States pursuant
to section 6673 in the amount of $7,500.
To reflect the foregoing,
An appropriate order and
order of dismissal and
decision will be entered.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011