- 9 - person, under the facts presented to the Court, should have known that the claimed deductions could not be sustained, and petitioners knew that. We do not and should not countenance the use of this Court as a vehicle for disgruntled litigants to proclaim the wrongdoing of another, their return preparer, as a basis for relief from penalties that were determined by respondent on facts that clearly are not sustainable. Golub v. Commissioner, T.C. Memo. 1999-288. Petitioners, therefore, have interfered with the Court's function to the detriment of other parties having cases with legitimate issues for the Court to consider. Petitioners have caused needless expense and wasted resources, not only for the Court, but for its personnel, respondent, and respondent's counsel. Under these circumstances, the penalty under section 6673 is warranted, and petitioners will be ordered to pay a penalty of $500 to the United States under section 6673(a). Reviewed and adopted as the report of the Small Tax Case Division. Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011