Robert and Clara Satriana - Page 14




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          issue.  Stubblefield v. Commissioner, supra.  On this record, the           
          Court sustains respondent on the section 6662(a) accuracy-related           
          penalties for the 2 years at issue.                                         
               Section 6673(a) authorizes the Court to require a taxpayer             
          to pay to the United States a penalty not exceeding $25,000 when,           
          in the Court's judgment, proceedings have been instituted or                
          maintained by the taxpayer primarily for delay or where the                 
          taxpayer's position in the proceeding is frivolous or groundless.           
          On this record, the Court considers petitioners' claim that they            
          should not be liable for the section 6662(a) penalties to be                
          frivolous and groundless.  Petitioners knew that a substantial              
          portion of the itemized deductions at issue was false and could             
          not be sustained.  Other circumstances noted above need not be              
          repeated here.                                                              
               The function of this Court is to provide a forum to decide             
          issues relating to liability for Federal taxes.  Any reasonable             
          and prudent person, under the facts presented to the Court,                 
          should have known that the claimed deductions could not have been           
          sustained, and petitioners knew that.  We do not and should not             
          countenance the use of this Court as a vehicle for a disgruntled            
          litigant to proclaim the wrongdoing of another, his return                  
          preparer, as a basis for relief from a penalty that was                     
          determined by respondent on facts that clearly are not                      
          sustainable.  Golub v. Commissioner, T.C. Memo. 1999-288.                   





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