- 18 - will reflect recomputation of the deficiencies to reduce the unreported income attributed to petitioner in accordance with this opinion. Even though petitioner’s tax liability will be reduced from that determined in the notices of deficiency, we conclude that a penalty under section 6673 should be imposed. The reduction in petitioner’s tax liability is not based on any evidence produced or arguments made by petitioner. The arguments made by petitioner have long been discredited and were asserted only for purposes of delay. Petitioner was warned in correspondence from respondent’s counsel and in the conference telephone call with the Court prior to trial that her arguments lacked merit and had been the basis for sanctions in prior cases. She nonetheless persisted in making them and failed to take advantage of opportunities provided to her to establish her correct tax liability. Based on the record in this case, a penalty is appropriate in the amount of $12,500. See Lipari v. Commissioner, T.C. Memo. 2000-280. To reflect the foregoing, An appropriate Order will be issued.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011