- 10 - and to delay their inevitable reckoning with respondent. Accordingly, we award a penalty to the United States under section 6673 in the amount of $5,000. See Roberts v. Commissioner, 118 T.C. 365, 373 (2002) (Court imposed a $10,000 penalty under section 6673(a) on taxpayer who instituted or maintained action under section 6330 primarily for delay); Davis v. Commissioner, T.C. Memo. 2001-87 (Court imposed a $4,000 penalty under section 6673(a) for frivolous and groundless arguments in lien and levy case). Accordingly, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011