- 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