- 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