- 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