- 14 - (A) proceedings before it have been instituted or maintained by the taxpayer primarily for delay, (B) the taxpayer’s position in such proceeding is frivolous or groundless, or (C) the taxpayer unreasonably failed to pursue available administrative remedies, the Tax Court, in its decision, may require the taxpayer to pay to the United States a penalty not in excess of $25,000. The various arguments that petitioner made in this case have been long discredited and patently were asserted for purposes of delay. His inconsistent pleadings show disregard for truthfulness and for the seriousness of these proceedings. We conclude that a penalty under section 6673(a) should be awarded to the United States in the amount of $10,000. To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011