- 7 -
Although petitioner is not liable for the section 6651(a)(2)
addition to tax, his position with respect to the substance of this
case is both frivolous and groundless. His insistence on pursuing
his fruitless argument has consumed the time and effort of both
this Court and the Commissioner, whose time and effort could
otherwise have been devoted to resolving bona fide claims of other
taxpayers. See Cook v. Spillman, 806 F.2d 948 (9th Cir. 1986).
Accordingly, pursuant to section 6673, we shall require petitioner
to pay a penalty to the United States in the amount of $1,000.
To reflect the foregoing,
An appropriate order and
decision will be entered.
Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011