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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.
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Last modified: May 25, 2011